Title
People vs. Exala
Case
G.R. No. 76005
Decision Date
Apr 23, 1993
A jeep stopped at a checkpoint led to a warrantless search, revealing marijuana. The driver claimed the bag wasn’t his, but the court upheld his conviction, ruling the search lawful and ownership irrelevant under drug laws.

Case Digest (G.R. No. 76005)
Expanded Legal Reasoning Model

Facts:

  • Circumstances of the checkpoint stop
    • On November 2, 1982, at about 8:15 PM, a police checkpoint was established in Cavite City under “Operation Bakal” to inspect for unlicensed firearms and other prohibited items.
    • A private jeep driven by Restituto B. Bocalan, with Jaime P. Fernandez and Rodelio C. Exala as passengers, was flagged down. Pfc. Ricardo Galang asked if they had firearms; they denied.
  • Discovery of contraband and prosecution
    • Galang shone a flashlight into the jeep, observed a bulging black leather bag, and noted the occupants’ silence and nervousness. He ordered the bag opened and found large quantities of marijuana.
    • The three were taken to the police station; laboratory tests confirmed over two kilograms of Indian hemp. They were charged under Section 4, Article II of R.A. 6425 (“The Dangerous Drugs Act of 1972,” as amended).
    • After trial, Bocalan was convicted as principal and sentenced to life imprisonment and a ₱25,000 fine. Fernandez and Exala were convicted as accomplices and received lighter penalties.

Issues:

  • Whether Bocalan’s claim that Exala alone owned the bag negates his liability for transporting marijuana.
  • Whether the warrantless search at the checkpoint violated Bocalan’s constitutional right against unreasonable searches and seizures, rendering the evidence inadmissible.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.