Facts:

The case involves Rudy Caballes y TaiAo as the petitioner against the Court of Appeals and the People of the Philippines as respondents. The events leading to the case occurred on June 28, 1989, in the Municipality of Pagsanjan, Laguna. On that night, at approximately 9:15 PM, police officers Sgt. Victorino Noceja and Pat. Alex de Castro were on routine patrol when they noticed a passenger jeep covered with kakawati leaves, which aroused their suspicion of smuggling. They flagged down the vehicle, which was driven by Caballes. Upon inquiry, Caballes did not respond and appeared nervous. The officers conducted a search of the jeep with Caballes' consent, discovering bundles of aluminum cable conductors weighing 700 kilograms, valued at P55,244.45, belonging to the National Power Corporation (NPC).

Caballes was arrested and later charged with theft in an Information filed on October 16, 1989. During the trial, he pleaded not guilty and presented a defense of denial and a...

Facts:

Incident Overview

On June 28, 1989, at around 9:15 p.m., Sgt. Victorino Noceja and Pat. Alex de Castro, while on routine patrol in Barangay Sampalucan, Pagsanjan, Laguna, spotted a passenger jeep covered with "kakawati" leaves. Suspicious of the unusual covering, they flagged down the vehicle, which was driven by the petitioner, Rudy Caballes. When asked about the cargo, Caballes appeared pale and nervous and did not respond. Upon inspection, the officers discovered bundles of 3.08 mm aluminum/galvanized conductor wires, weighing 700 kilos and valued at P55,244.45, owned by the National Power Corporation (NPC). Caballes claimed the wires came from Cavinti, Laguna, and he was subsequently arrested and detained for seven days.

Defense of Petitioner

Caballes denied the charges and claimed he was part of an entrapment operation. He testified that he was a NARCOM civilian agent and had informed his superior, Sgt. Callos, about the suspicious activity. He alleged that he was instructed to proceed with transporting the wires, which were loaded by five masked men, and that he was promised P1,000 for the job. However, he was intercepted by the police before reaching his destination.

Trial Court Decision

The Regional Trial Court (RTC) found Caballes guilty of theft and sentenced him to imprisonment ranging from 2 years, 4 months, and 1 day to 10 years, with an order to indemnify NPC for P55,244.45. The Court of Appeals affirmed the conviction but modified the penalty and deleted the indemnity, as the stolen materials were recovered.

Issue:

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Ruling:

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Ratio:

1. Warrantless Search of Moving Vehicles: While warrantless searches of moving vehicles are permissible under certain circumstances, such as when there is probable cause to believe the vehicle contains contraband or evidence of a crime, the police in this case lacked such probable cause. The mere fact that the vehicle was covered with leaves did not constitute sufficient grounds for a warrantless search.

2. Plain View Doctrine: The cable wires were not in plain view, as they were concealed in sacks and covered with leaves. The police had to physically inspect the vehicle to discover the wires, which goes beyond the scope of a valid plain view seizure.

3. Consented Search: The Court found no clear and convincing evidence that Caballes voluntarily consented to the search. His passive submission to the search did not amount to a valid waiver of his constitutional rights against unreasonable searches and seizures.

4. Exclusionary Rule: Evidence obtained in violation of constitutional rights is inadmissible. Since the search was unconstitutional, the cable wires could not be used as evidence against Caballes, leading to his acquittal.

Conclusion:

The Supreme Court emphasized the importance of protecting constitutional rights against unreasonable searches and seizures. The absence of probable cause and the lack of valid consent rendered the search illegal, and the evidence obtained therefrom was inadmissible. Consequently, Caballes was acquitted due to insufficient evidence to prove his guilt beyond reasonable doubt.