People of the Philippines v.

SAPLA
G.R. No. 244045, June 16, 2020
CAGUIOA, J.:
Fact:
A police officer on duty in the Regional Public Safety Battalion (RPSB)
received a phone call from a concerned citizen claiming that a certain
individual would be transporting illegal drugs (marijuana) from Kalinga to
Isabela. The PNP together with the PDEA proceeded to the Talaca
detachment for their operation.

At 1:00 in the afternoon, the RPSB hotline received a tip on the appearance
of the suspect: he is wearing a white collared shirt with green stripes, a red
ball cap and was carrying a blue sack in a jeepney with the plate number
AYA 270 bound for Roxas. The joint checkpoint was strategically organized
for this operation. Upon its arrival, the police flagged down the jeepney and
affirmed the ownership of Sapla on the blue sack. The police requested
Sapla to open the sack for them to discover 4 bricks of suspected marijuana
leaves. Subsequently, RTC convicted Sapla on violating RA 9165 or the
“Dangerous Drugs Act”.

The accused-appellant filed an appeal on the CA on the grounds that the

search and seizure made by the PNP and PDEA was warrantless.

CA denied accused-appellant’s appeal and affirmed the RTC’s decision,

stating that the warrantless search is valid because it is a search of a moving
vehicle.

The accused-appellant filed an appeal on the Supreme Court assailing the

decision of the Court of Appeals on April 18, 2018 which affirmed the
judgement of the Regional Trial Court.

Issue:

Whether the search and seizure done by the police is valid considering there
are no warrants.

Ruling:

NO. “The Court finds for accused-appellant Sapla and immediately orders
his release from incarceration.”

By Constitutional design, the accused is afforded with the presumption of

innocence – for the State to prove the guilt of the accused. The Court finds
error in the judgement of the CA that the search is an example of a search of
a moving vehicle.

According to jurisprudence, “warrantless search and seizure of moving

vehicles are allowed in recognition of the impracticability of securing a
warrant under said circumstances as the vehicles can be quickly moved out
of the locality or jurisdiction in which the warrant may be sought. Peace
officers, in such cases, however, are limited to routine checks where the
examination of the vehicle is limited to visual inspection.” An extensive
search of the vehicle is allowed only when “the officers made it upon
probable cause, i.e., upon a belief reasonably arising out of the
circumstances known to the seizing officer, that an automobile or other
vehicle contains an item, article or object which by law is subject to seizure
and destruction.”

In the case at bar, it cannot be disputed that the target of the seizure is the
accused-appellant but someone who matched the description of the tip given
by the concerned citizen. The reception of a text message from an
anonymous person is not a probable cause that enables the authority to
conduct an extensive and intrusive search without a warrant. Police officers
must observe facts rather than mere information passed to him/her since it
goes against the nature of probable cause.