People of the Philippines vs Ramon Solomon

written by Howard

G.R. No. 246579 – Remedial Law – Criminal Procedure – Rule 113; Arrest – Valid Warrantless Arrest; Hot Pursuit – Personal Knowledge May Be Obtained by Viewing a Security Footage 

Ramon Solomon robbed a grocery store and the incident was caught by a closed circuit TV camera (CCTV). The grocery attendant called the police. The police viewed the CCTV footage and was able to determine the direction to which Solomon went. The police likewise asked around until they were able to discover the identity of Solomon including his address. Based on the information they gathered, the police was able to go to Solomon’s house before he could. When the police saw Solomon arriving home, they arrested him right there and then. Thereafter, they frisked his person and was able to recover from him an unlicensed firearm.

ISSUE: Whether or not there is a valid warrantless arrest.

HELD: Yes. The police may not have actually witnessed the happening of the crime real time as they merely responded to a report. However, by viewing the CCTV footage, they have acquired personal knowledge of the commission of a crime and that the person recorded in the CCTV has committed it. Upon conducting the immediate operation, they were able to identify Solomon and caused his immediate arrest. The circumstances in this case show that the police officers acquired personal knowledge that a crime had just been committed and an element of immediacy was present in effecting the arrest. Thus, the elements of a valid hot pursuit warrantless arrest were present. There was a continuous and unbroken pursuit.

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