Title
Epie, Jr. vs. Ulat-Marredo
Case
G.R. No. 148117
Decision Date
Mar 22, 2007
Petitioners charged with illegal lumber possession; warrantless search upheld due to probable cause under moving vehicle exception, evidence deemed admissible.
A

Case Digest (G.R. No. 148117)

Facts:

  • Nature of the Case
    • Mabini Epie, Jr. and Rodrigo Palasi (petitioners) were charged with violation of Section 68 of Presidential Decree No. 705, as amended, for unlawfully possessing and transporting 870 bd. ft. of Benguet pine lumber without authority or permit from the Department of Environment and Natural Resources (DENR).
    • The lumber was valued at Twenty Four Thousand Three Hundred Sixty Pesos (P24,360.00) and was the property of the Republic of the Philippines.
  • Incident Details and Arrest
    • On September 6, 1998, at around 2:30 PM, SPO2 Alberto Ngina of the Philippine National Police (PNP) Tublay Station received confidential information that a jeepney (Plate No. AYB 117) was loaded with Benguet pine lumber at Km. 96, Atok, Benguet.
    • SPO2 Ngina informed SPO4 Rentao Quitoriano and SPO1 Domingo Pulig, who established a checkpoint at Acop, Tublay, Benguet.
    • At around 4:00 PM, the jeepney was spotted heading to La Trinidad. When flagged down, it did not stop and was pursued until Shilan, La Trinidad, where it eventually halted.
    • The police found five persons inside the vehicle. Underneath assorted vegetables such as womboc (Chinese cabbage) and chili, pieces of lumber were discovered.
    • The driver and others admitted they had no permit to transport the lumber.
    • Police arrested and investigated petitioners along with Marso Insiong Dumpit, Armando Palasi, and Ben Arinos; only the petitioners were charged.
  • Trial and Motions
    • Petitioners pleaded not guilty and trial ensued.
    • After prosecution presented evidence, petitioners filed a "Motion to Suppress Evidence of the Prosecution," arguing the lumber was seized illegally without a warrant.
    • The Regional Trial Court (RTC), Branch 10, La Trinidad, Benguet, presided by Judge Nelsonida T. Ulat-Marredo, denied the motion in Resolutions dated July 26, 1999, and September 27, 1999.
  • Appeal to the Court of Appeals
    • Petitioners filed a petition for certiorari and prohibition with the Court of Appeals (CA), docketed as CA-G.R. SP No. 55684, challenging the RTC resolutions.
    • On September 15, 2000, the CA dismissed the petition, ruling the warrantless search was valid and the seized lumber admissible as evidence.
    • A motion for reconsideration was filed by petitioners but denied by the CA on April 11, 2001.
  • Petition Before the Supreme Court
    • Petitioners elevated the case to the Supreme Court via Petition for Review on Certiorari.
    • The sole issue raised was whether the police had probable cause to stop and search the jeepney without a warrant.

Issues:

  • Whether the police officers had probable cause to believe the jeepney was loaded with illegal lumber to justify the warrantless stop and search.
  • Whether the warrantless search and seizure in this case violated petitioners' constitutional right against unreasonable searches and seizures.
  • Whether the evidence seized (Benguet pine lumber) can be admitted in evidence against the accused despite being seized without a warrant.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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