For
the warrantless arrest under Section 5 (b) Rule 113 of the rules of Criminal
Procedure to be valid, two requisites must concur: (1) the offender
has just committed an offense; and (2) the arresting peace officer or
private person has personal knowledge of facts indicating that the person to be
arrested has committed it. Personal
knowledge of facts must be based on probable cause, which means an
actual belief or reasonable grounds of suspicion. The grounds of suspicion are reasonable when, in the absence of actual
belief of the arresting officers, the suspicion that the person to be arrested
is probably guilty of committing the offense is based on actual facts, i.e.,
supported by circumstances sufficiently strong in themselves to create the
probable cause of guilt of the person to be arrested. A reasonable suspicion, therefore, must be founded on probable cause,
coupled with good faith on the part of the peace officers making the arrest. (ABELITA
III vs. DORIA, G.R. No. 170672, August 14, 2009, First Division, Carpio, J.).
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