Committed and personal knowledge of facts and

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committed" and ''personal knowledge of facts and circumstances that the person to be arrested committed it" depended on the particular circumstances of the case. However, we note that the element of ''personal knowledge of facts or circumstances" under Section S(b ), Rule 113 of the Revised 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 or circumstances" is the required element of immediacy within which these facts or circumstances should be gathered. This required time element acts as a safeguard to ensure that the police officers have gathered the facts or perceived the circumstances within a very limited time frame. This guarantees that the police officers would have no time to base their probable cause finding on facts or circumstances obtained after an exhaustive investigation. The reason for the element of the immediacy is this - as the time gap from the commission of the crime to the arrest widens, the pieces of information gathered are prone to become contaminated and subjected to external factors, interpretations and hearsay. On the other hand, with the element of immediacy imposed under Section 5(b), Rule 113 of the Revised Rules of Criminal Procedure, the police officer's determination of probable cause would necessarily be limited to raw or uncontaminated facts or circumstances, gathered as they were within a very limited period of time. The same provision adds another safeguard with the requirement of probable cause as the standard for evaluating these facts of circumstances before the police officer could effect a valid warrantless arrest. Warrantless arrest valid because of time element. Based on the police blotter entry taken at 4:15 a.m. on February 20, 2005, the date that the alleged crime was committed, the petitioners were brought in for investigation at the Batasan Hills Police Station. The police blotter stated that the alleged crime was committed at 3:15 a.m. on February 20, 2005, along Kasiyahan St., Brgy. Holy Spirit, Quezon City. 120
The time of the entry of the complaint in the police blotter at 4:15 a.m., with Atty. Generoso and the petitioners already inside the police station, would connote that the arrest took place less than one hour from the time of the occurrence 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 when they arrived at the scene of the crime is corroborated by the petitioners' admissions that Atty: Generoso indeed suffered blows from petitioner Macapanas and his brother Joseph Macapanas, although they asserted that they did it in self-defense against Atty. Generoso.

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