Warrantless arrest without personal knowledge

Since the accused was arrested without a warrant, the inquiry must now be whether a valid warrantless arrest was effected in accordance with Rule 113 of the Rules of Criminal Procedure. The first and last conditions enumerated in the Rule are not applicable in this case; and under the facts herein, neither does the second condition apply. Luna's basis for arresting Melvida was the bio-data sheet with Melvida's name on it found at the crime scene. By no means can this indictae that Melvida committed the offense charged. It does not even connote that Melvida was at the crime scene for the bio-data sheet could have been obtained by anyone and left at the crime scene long before or after the crime was committed. Luna, therefore, had no personal knowledge of facts indicating Melvida's guilt; at best, he had an unreasonable suspicion. Melvida's arrest was thus illegal. [G.R. No. 117397. November 13, 1996]