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committed" and ''personal knowledge of facts and circumstances that theperson to be arrested committed it" depended on the particularcircumstances of the case. However, we note that the element of ''personalknowledge of facts or circumstances" under Section S(b ), Rule 113 of theRevised Rules of Criminal Procedure requires clarification.Clincher in the element of personal knowledge in warrantless arrest.In other words, the clincher in the element of ''personal knowledge of facts orcircumstances" is the required element of immediacy within which these factsor circumstances should be gathered. This required time element acts as asafeguard to ensure that the police officers have gathered the facts orperceived the circumstances within a very limited time frame. Thisguarantees that the police officers would have no time to base their probablecause finding on facts or circumstances obtained after an exhaustiveinvestigation.The reason for the element of the immediacy is this - as the time gap fromthe commission of the crime to the arrest widens, the pieces of informationgathered are prone to become contaminated and subjected to externalfactors, interpretations and hearsay. On the other hand, with the element ofimmediacy imposed under Section 5(b), Rule 113 of the Revised Rules ofCriminal Procedure, the police officer's determination of probable causewould necessarily be limited to raw or uncontaminated facts orcircumstances, gathered as they were within a very limited period of time.The same provision adds another safeguard with the requirement of probablecause as the standard for evaluating these facts of circumstances before thepolice officer could effect a valid warrantless arrest.Warrantless arrest valid because of time element. Based on the policeblotter entry taken at 4:15 a.m. on February 20, 2005, the date that thealleged crime was committed, the petitioners were brought in forinvestigation at the Batasan Hills Police Station. The police blotter stated thatthe alleged crime was committed at 3:15 a.m. on February 20, 2005, alongKasiyahan St., Brgy. Holy Spirit, Quezon City.120
The time of the entry of the complaint in the police blotter at 4:15 a.m., withAtty. Generoso and the petitioners already inside the police station, wouldconnote that the arrest took place less than one hour from the time of theoccurrence of the crime. Hence, the CA finding that the arrest took place two(2) hours after the commission of the crime is unfounded.The arresting officers' personal observation of Atty. Generoso's bruises whenthey arrived at the scene of the crime is corroborated by the petitioners'admissions that Atty: Generoso indeed suffered blows from petitionerMacapanas and his brother Joseph Macapanas, although they asserted thatthey did it in self-defense against Atty. Generoso.