12/17/24, 5:51 PM Manibog vs.
People
Title
Manibog vs. People
Case Decision Date
G.R. No. 211214 Mar 20, 2019
The Supreme Court affirms the conviction of Larry Sabuco Manibog for illegal firearm
possession during the election period, validating the warrantless search and arrest
based on police observations and tips.
Jur.ph - Case Digest (G.R. No. 211214)
Comprehensive
Facts:
Larry Sabuco Manibog (petitioner) vs. People of the Philippines (respondent).
Supreme Court decision dated March 20, 2019.
Incident occurred on March 17, 2010, in Brgy. Madamba, Dingras, Ilocos Norte.
Manibog charged with violating the Omnibus Election Code regarding the gun ban
from January 10, 2010, to June 9, 2010.
Accused of unlawfully carrying a .45 caliber pistol without a permit from the
Commission on Elections.
Manibog pleaded not guilty during arraignment.
Case focused on the legality of the search and seizure of the firearm.
Police Chief Inspector Randolph Beniat received a tip about Manibog carrying a gun.
Upon approach, Beniat noticed a bulge on Manibog's waist, suspected to be a firearm.
A pat-down confirmed the presence of the gun, leading to Manibog's arrest.
The Regional Trial Court found him guilty, ruling the warrantless search was lawful.
The Court of Appeals upheld the decision, prompting Manibog to file a Petition for
Review on Certiorari to the Supreme Court.
Issue:
(Unlock)
Ruling:
The Supreme Court denied the petition, affirming the lower courts' decisions.
The warrantless search was deemed valid, ...(Unlock)
https://jur.ph/jurisprudence/v/digest/manibog-v-people?q=people+vs+manibog 1/2
12/17/24, 5:51 PM Manibog vs. People
Ratio:
The Supreme Court highlighted that a valid "stop and frisk" search requires a totality of
suspicious circumstances.
Article III, Section 2 of the 1987 Philippine Constitution protects against unreasonable
searches and seizures, necessitating a warrant based on probable cause.
Exceptions to warrantless searches include searches incidental to lawful arrests and
those under the "plain view" doctrine.
The Court found probable cause for the stop ...
Unlock Full Case Digest
https://jur.ph/jurisprudence/v/digest/manibog-v-people?q=people+vs+manibog 2/2
