Name: Ada, Ma. Rasill U.
HNU College of Law
Subject: JD 402 [A] Criminal Law II J.D. 1
Case Name:
The United States, petitioner vs. Dionisio Santos, respondent.
Supreme Court En Banc, Malcolm, J
G.R. No. 12779
September 10, 1917
Doctrine: Art. 124. Arbitrary detention - The court established that peace officers in
the Philippines have the same powers as constables under Anglo-
American common law. They are authorized to make arrests without a
warrant under circumstances such as when there is reasonable ground
of suspicion that a person has committed or is about to commit a crime
or breach of the peace. However, the officer must act in good faith and
with reasonable grounds for suspicion.
Facts: Dionisio Santos, a policeman of Pateros, Province of Rizal, acting under
the orders of his chief who desired to put a stop to pilfering in a certain
locality, patrolled this district, and about midnight, seeing two persons in
front of an uninhabited house and then entering an uninhabited camarin,
arrested them without warrant, although no crime had been committed,
and took them to the municipal presidencia where they were detained in
the jail for six or seven hours when they were released.
The trial court found the accused guilty of coercion, but the Court of
Appeals reversed the decision and acquitted the accused.
Issue/s: Whether or not Dionisio Santos is guilty of coercion as found by the trial
court.
Ruling: No. The Court reversed the judgment of the trial court and
acquitted the accused, with costs de officio.
The Court applied the Common Law rule on the arrest without warrant of
suspicious night-walkers, which allows peace officers to arrest and
detain such individuals for examination. The Court held that the accused
cannot justify the arrest by acting in obedience to legal process, but he
can justify it under the rule that peace officers may pursue and arrest
without warrant any person found in suspicious places or under
suspicious circumstances reasonably tending to show that such person
has committed or is about to commit any crime or breach of the peace.
The Court emphasized that even if the suspected person is later found to
be innocent, the peace officer is not liable if he acted in good faith. One
should not expect too much of an ordinary policeman and a peace officer
making a mistake in good faith should be exculpated.
