People vs Leangsiri [G.R. No. 112659] Case Digest

 

People vs Leangsiri

G.R. No. 112659

 

Facts:

Accused Leangsiri was arrested at the arrival area of the Ninoy Aquino International Airport (NAIA). He was in the act of bringing into the country 8,225.31 grams of heroin hidden under the false bottom of a black suitcase. He informed the authorities that he was to deliver the contraband to three (3) people at the Las Palmas Hotel in Manila.  The team and agents of the Bureau of Customs proceeded to the Las Palmas Hotel, where they allowed Leangsiri to check into Room 504 with the confiscated black suitcase containing the heroin.

Amidu, Omogbolahan and Bhola, arrived at the hotel. They knocked on the door of Room 504. Leangsiri stood up from the bed in which he sat, opened the door, and let the three appellants in.  Leangsiri opened the suitcase and displayed its contents to his visitors.Appellants briefly examined the black suitcase and two (2) transparent plastic bags which contained the heroin. After the examination, Leangsiri closed the suitcase and handed it over to appellants. Appellants started to leave the hotel room with the contraband when Gapiangao and Balneg barged out of the washroom, identified themselves as NARCOM agents, and made the arrest.

Accompanied by the hotel's owner and security officer, Samala (one of NARCOM agents) searched appellant Amidu's room. Tucked within the pages of her telephone and address book was a piece of paper with the name "SUCHINDA LEANGSIRI" written on it.  The paper and Amidu's other possessions were confiscated. 

The trial court find the herein appellants guilty of the crime charged.

 

Issue:

Whether or not the piece of paper found in Amidu's hotel room, with the name "SUCHINDA LEANGSIRI" written on it, should be admitted by the court.

 

Held:

No.

 

Ratio:

The Revised Rules of Court provide that "(a) person lawfully arrested may be searched for dangerous weapons or anything which may be used as proof of the commission of an offense, without a search warrant.  

SC held that the warrantless search made by the authorities on the accused's apartment which was located a few blocks away from where she was arrested was illegal for being "an untenable violation, if not nullification, of the basic constitutional right and guarantee against unreasonable searches and seizures."

The inadmissibility of evidence obtained in a warrantless search incident to a lawful arrest outside the suspect's person and the premises under his immediate control.