AN ACCUSED IS ESTOPPED FROM ASSAILING ANY IRREGULARITY OF HIS ARREST IF HE FAILS TO RAISE THIS ISSUE OR TO MOVE FOR THE QUASHAL OF THE INFORMATION AGAINST HIM ON THIS GROUND BEFORE ARRAIGNMENT.

Any objection involving a warrant of arrest or the procedure by which the court acquired jurisdiction over the person of the accused must be made before he enters his plea; otherwise, the objection is deemed waived. At any rate, the illegal arrest of an accused is not sufficient cause for setting aside a valid judgment rendered upon a sufficient complaint after a trial free from error.  It will not even negate the validity of the conviction of the accused.  True, the Bill of Rights under the present Constitution provides in part:

SEC. 2. The right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures of whatever nature and for any purpose shall be inviolable, and no search warrant or warrant of arrest shall issue except upon probable cause to be determined personally by the judge after examination under oath or affirmation of the complainant and the witnesses he may produce, and particularly describing the place to be searched and the persons or things to be seized.

However, a settled exception to the right guaranteed by the above-stated provision is that of an arrest made during the commission of a crime, which does not require a previously issued warrant.  Such warrantless arrest is considered reasonable and valid under Section 5 (a), Rule 113 of the Revised Rules on Criminal Procedure, to wit:

Sec. 5.  Arrest without warrant; when lawful.   a peace office of a private person may, without a warrant, arrest a person:

(a)  When, in his presence, the person to be arrested has committed, is actually committing, or is attempting to commit an offense;

For the exception in Section 5 (a), Rule 113 to operate, this Court has ruled that two (2) elements must be present: (1) the person to be arrested must execute an overt act indicating that he has just committed, is actually committing, or is attempting to commit a crime; and (2) such overt act is done in the presence or within the view of the arresting officer. (ABRAHAM MICLAT JR. VS. PEOPLE OF THE PHILS., G.R. NO. 176077, AUGUST 31, 2011, PERALTA, J.).