Wednesday, December 27, 2023

People vs. Mentoy, G.R. No. 223140, September 04, 2019, [Case Digest]

 

People vs. Mentoy,

G.R. No. 223140, September 04, 2019,

First Division [Bersamin, C.J.]

Facts:

            On May 31, 2008, at about 8 a.m., PSI Socrates briefed the operation team (team). At about 4:30 p.m., the informant relayed to the team that accused-appellant will be boarding a Charing 19 shuttle van (van) with plate number VRA 698. Thus, the team proceeded to the National Highway, Barangay Malatgao, Nan-a, Palawan. At a distance of one (1) to two (2) meters, PO1 Rosales, while on board his motorcycle, saw accused-appellant board the van. PO1 Rosales flagged down the van as it approached them. The team introduced themselves as police officers. They declared that they were conducting a checkpoint because of information about persons transporting illegal drugs. PO1 Rosales told the driver that they will check the van passengers. The driver then opened the van's side door. PO1 Rosales asked the van passengers who among them was Rose. Accused-appellant replied, "Aka po" (I am). PO1 Rosales asked accused-appellant where her baggage was. Accused-appellant apprehensively requested the driver to hand her the pink bag placed at the rear portion of the van. SPO2 Felizarte and PO1 Rosales, however, noticed that accused-appellant transferred a block-shaped bundle, wrapped in yellow cellophane and brown tape, from the pink bag to a black one. SPO2 Felizarte and PO1 Rosales suspected this bundle to contain marijuana leaves. Accused-appellant then placed the black bag on a vacant seat beside her. SPO2 Felizarte also noticed that accused-appellant panicked and tried to get down from the van, but he and PO1 Rosales restrained her. Afterwards, PO1 Rosales called Barangay Captain Ernesto Maiguez (Brgy. Captain Maiguez) to proceed to the area.

            When Brgy. Captain Maiguez arrived, SPO2 Felizarte and PO1 Rosales asked him if he knew accused-appellant. Brgy. Captain Maiguez said he knew accused-appellant as a rice seller who resided in Barangay Malatgao where he was chairman. The police officers asked Brgy. Captain Maiguez to pick up the black bag, which accused-appellant held beside her. Brgy. Captain Maiguez got (the) said bag and placed it by the road. SPO2 Felizarte requested him to open it. Brgy. Captain Maiguez opened said bag in the presence of accused-appellant and the other van passengers. PO1 Rosales took photographs while said bag was being opened. The black bag contained, inter alia: (a) one (1) L-shaped bundle wrapped in yellow cellophane and brown tape; (b) one (1) block-shaped bundle wrapped in newspaper; and (c) one (1) sachet (covered with tissue paper), all suspected to contain marijuana leaves. The police officers smelled the bundles and sachet and confirmed that these contained marijuana leaves. The police officers returned the items inside the black bag. They arrested and informed accused-appellant that she violated Republic Act (R.A.) No. 9165 and apprised the latter of her constitutional rights. Since accused-appellant lived near the crime scene, the police officers brought her and the seized items immediately to the police station to avoid any untoward incident.

            PO1 Rosales carried the black bag from the crime scene to the police station. Thereat, PO1 Rosales prepared an inventory of the seized items in the presence of a media representative and Brgy. Captain Maiguez. PO1 Rosales also marked the L-shaped bundle as "ADR-1", blocked-shaped bundle as "ADR-2", and sachet as "ADR-3", respectively, in the presence of accused-appellant. PO1 Rosales brought the bundles and sachet to the Palawan Crime Laboratory (crime laboratory) where Forensic Chemist and Police Chief Inspector Mary Jane Cordero (PCI Cordero) examined the seized items. She found the contents of the bundles and sachet positive for marijuana and prepared Chemistry Report No. D-005-08 stating her findings.

            RTC convicted the accused-appellant as charged.  CA rendered the assailed decision affirming the conviction of the accused-appellant. It opined that a search could precede an arrest if the police officers had probable cause to effect the arrest; that the warrantless search conducted on the personal effects of the accused­-appellant had been an incident of her lawful arrest; and that the Prosecution had adequately established the crucial links in the chain of custody.

 

Issue:

            Whether the marijuana leaves supposedly taken from her bag were inadmissible in evidence pursuant to the exclusionary rule.

 

Held:

            No; a lawful arrest must precede a warrantless search conducted upon the personal effects of an individual. The process cannot be reversed. Hence, the search must rest on probable cause existing independently of the arrest.

            Generally, there can be no valid arrest, search and seizure without a warrant issued by a competent judicial authority. The warrant, to be issued by a judge, must rest upon probable cause - the existence of facts indicating that the person to be arrested has committed a crime, or is about to do so; or the person whose property is to be searched has used the same to commit crime, and its issuance must not be based on speculation, or surmise, or conjecture,,,, or hearsay. The right to be protected from unreasonable searches and seizures is so sacred that no less than Section 2, Article III of the Constitution declares the right to be inviolable, and for that reason expressly prohibits the issuance of any search warrant or warrant of arrest except upon probable cause to be personally determined by a judge after examination under oath or affirmation of the complainant and the witnesses he may produce, and particularly describing the place to be searched, and the persons or things to be seized.

            To enforce such inviolable right, Section 3(2), Article III of the Constitutions enunciates the exclusionary rule by unqualifiedly declaring that "[a]ny evidence obtained in violation of this or the preceding section shall be inadmissible for any purpose in any proceeding." The exclusionary rule is intended to deter the violation of the right to be protected from unreasonable searches and arrest.

            We are mindful that the guarantee against warrantless arrests, and warrantless searches and seizures admit of some exceptions. One such exception relates to arrests, searches and seizures made at a police checkpoint. Indeed, routine inspections made at checkpoints have been regarded as permissible and valid, if the inspections are limited to the following situations: (a) where the officer merely draws aside the curtain of a vacant vehicle parked on the public fair grounds; (b) simply looks inside a vehicle; (c) flashes a light into the vehicle without opening its doors; (d) where the occupants of the vehicle are not subjected to a physical or body search; (e) where the inspection of the vehicle is limited to a visual search or visual inspection; and (f) where the routine check is conducted in a fixed area.

            Warrantless search of the accused-appellant's personal belongings was not based on probable cause.  For sure, the transfer made by the accused-appellant of the block­ shaped bundle from one bag to another should not be cited to justify the search if the search had earlier commenced at the moment PO1 Rosales required her to produce her baggage. Neither should the officers rely on the still-unverified tip from the unidentified informant, without more, as basis to initiate the search of the personal effects. The officers were themselves well aware that the tip, being actually double hearsay as to them, called for independent verification as its substance and reliability, and removed the foundation for them to rely on it even under the circumstances then obtaining. In short, the tip, in the absence of other circumstances that would confirm their suspicion coming to the knowledge of the searching or arresting officer, was not yet actionable for purposes of effecting an arrest or conducting a search.

            The general rule is that an arrest or search and seizure should be effected upon a judicial warrant. A lawful warrantless arrest may be effected by a peace officer or private person but only when any of the exceptions listed in Section 5, Rule 113 of the Rules of Court to the rule requiring a warrant of arrest to be issued is applicable.

            On its part, the CA upheld the warrantless arrest on the basis of the accused-appellant having been. caught in flagrante delicto, the situation covered by Section 5(a), supra. An arrest made in flagrante delicto means that the arrestee is caught in the very act of committing the crime, and the phrase necessarily implies that the positive identification of the culprit has already been done by an eyewitness or eyewitnesses. Such identification constitutes direct evidence of culpability because it "proves the fact in dispute without the aid of any inference or presumption." But we find otherwise, because there was no direct evidence on the identity of the culprit as of the time of the search simply because the officers still had to know who Rose was from among the passengers.

            Also, the officers did not immediately effect the arrest of the accused­ appellant once she had identified herself as Rose, and the only explanation for this was that they still had to check if her bag had really contained marijuana. As earlier noted, they claimed seeing her transferring from one bag to another the block-shaped bundle, wrapped in yellow cellophane and brown tape, but their vaunted suspicion of the contents being marijuana was SPO2 Felizarte's afterthought justification considering that the contents of the bundle were not then visible on plain sight. It is noteworthy in this regard that the contents would be revealed as marijuana only after the barangay captain had opened the bag.

            The arrest of the accused-appellant did not justify the search of the personal belongings because the arrest did not precede the search. Section 13, Rule 126 of the Rules of Court, clearly states that "[a] person lawfully arrested may be searched for dangerous weapons or anything which may have been used or constitute proof in the commission of an offense without a search warrant." Accordingly, there should first be a lawful arrest before the warrantless search can be made; the process cannot be reversed.  As such, the search made against the accused-appellant would be valid only if sufficient probable cause to support it existed independently of the arrest.

            What the foregoing disquisition indicates is that the arresting officers plainly ignored the constitutional and statutory limitations prescribed for a valid search at a checkpoint. They effected the warrantless search of the personal effects of the accused-appellant without sufficient probable cause, and on that basis arrested her.

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