Primary Holding

A peace officer who arrests a person without a warrant based on reasonable suspicion and in good faith is not liable, even if the arrested person is later found innocent.

Background

Dionisio Santos, a policeman in Pateros, Rizal, was tasked with preventing pilfering in a certain area. While patrolling, he saw two individuals near an uninhabited house and arrested them without a warrant, detaining them for six to seven hours before releasing them. The trial court convicted Santos of coercion, but the Supreme Court reviewed the case to determine if his actions were justified.

Facts

• 1. Santos, a policeman, arrested two individuals without a warrant late at night based on their suspicious behavior near an uninhabited house. The individuals were detained for six to seven hours before being released. No crime had been committed at the time of the arrest.

Arguments of the Petitioners

• 1. Santos argued that he acted in good faith and within his duties as a peace officer, arresting the individuals based on reasonable suspicion to prevent potential crimes.

Arguments of the Respondents

• 1. The prosecution argued that Santos had no legal basis to arrest the individuals without a warrant, as no crime had been committed, and thus, he was guilty of coercion.

Issues

• 1. Whether Santos was guilty of coercion for arresting the individuals without a warrant, or if his actions were justified under the principles of reasonable suspicion and good faith.

Ruling

• 1. The Supreme Court reversed the trial court's decision, acquitting Santos. The Court held that peace officers may arrest individuals without a warrant if there is reasonable suspicion that they have committed or are about to commit a crime. Santos acted in good faith and within the scope of his duties, and thus, he was not liable for coercion.

Doctrines

• 1. Reasonable Suspicion: Peace officers may arrest without a warrant if there is reasonable suspicion supported by circumstances that warrant belief in the person's guilt.
• 2. Good Faith: Officers acting in good faith and within their duties are protected from liability, even if the arrested person is later found innocent.

Precedents Cited

• 1. U.S. vs. Fortaleza (1909): Cited to explain the powers of peace officers in the Philippines, aligning with the Anglo-American Common Law.
• 2. U.S. vs. Sanchez (1914): Cited to show that the principles of Spanish law on arrests are not essentially different from those of the Common Law.

Statutory and Constitutional Provisions

• 1. Administrative Code (1916, Sec. 2204; 1917, Sec. 2258): Municipal policemen are enjoined to "exercise vigilance in the prevention of public offenses."