The Supreme Court of the Philippines has reiterated that a violation of ordinances or regulations alone does not justify a valid warrantless search and seizure, especially when the offense does not carry a penalty of imprisonment.

In a decision penned by Associate Justice Mario V. Lopez, the Court's Second Division acquitted Angelito Ridon of illegal possession of a firearm, ruling that the firearm seized from him was inadmissible due to an unlawful search and seizure.

Ridon was driving a motorcycle when police officers signaled him to stop after he attempted to turn onto a one-way street. Instead of complying, Ridon made a U-turn, prompting a chase by two police officers, Police Officer III Sherwin Clete Limbauan (PO3 Limbauan) and PO3 Harley Manguin Abuan, along with a Bantay Bayan. Ridon was eventually cornered after falling off his motorcycle. As he reached for something at his side, the Bantay Bayan apprehended him, while the officers drew their firearms. A subsequent frisk by PO3 Limbauan uncovered a revolver without a serial number, leading to Ridon’s arrest.

The Regional Trial Court found Ridon guilty of illegal possession of a firearm, citing that he lacked the required license in violation of Republic Act No. 10591, or the Comprehensive Firearms and Ammunition Regulation Act. This conviction was upheld by the Court of Appeals, which ruled that the warrantless search was lawful, being a consequence of a valid arrest after Ridon tried to evade the police.

However, the Supreme Court overturned this ruling, declaring the warrantless search invalid. Under Rule 126, Section 13 of the Rules of Court, warrantless searches and seizures are permissible only if conducted as part of a lawful arrest. In this case, the pursuit of Ridon was based solely on his traffic violation for entering a one-way street—a violation that does not warrant an arrest but merely the confiscation of a driver’s license. Since no lawful arrest was made, the subsequent search was also deemed illegal.

The Court further clarified that the warrantless search could not be justified as a "stop-and-frisk" operation. For such searches to be valid, there must be suspicious or unusual conduct observed by the police, with at least two reasonable suspicious circumstances. In Ridon’s case, his attempt to flee and his movement to draw something from his waist did not sufficiently indicate that he was hiding a prohibited item. The absence of any visible bulge or object that could have been identified as a weapon also undermined the justification for the search.

Given that the firearm was seized illegally, it was ruled inadmissible in court. With no other admissible evidence, the Supreme Court acquitted Ridon.