Title
People vs. Marti
Case
G.R. No. 81561
Decision Date
Jan 18, 1991
Andre Marti convicted for shipping marijuana to Zurich; evidence admissible as search was by private individual, not government; defenses deemed implausible.

Case Digest (G.R. No. 81561)
Expanded Legal Reasoning Model

Facts:

  • Initial Transaction
    • On August 14, 1987, between 10:00 and 11:00 a.m., Andre Marti (appellant) and his common‐law wife approached “Manila Packing and Export Forwarders” in Ermita, Manila, with four gift‐wrapped packages.
    • The appellant declared the contents as books, cigars, and gloves, to be shipped to “Walter Fierz, Mattackerstr II, 8052 Zurich, Switzerland,” and refused the proprietor’s request to inspect the packages.
  • Private Inspection by Job Reyes
    • Following standard procedure, proprietor Job Reyes opened the sealed corrugated box before delivery to the Bureau of Customs or Posts. He detected a peculiar odor, squeezed a bundle labeled as gloves, and discovered dried leaves enclosed in a cellophane wrapper.
    • Reyes extracted several grams of the substance, wrote a report to the NBI, and delivered the sample around 1:30 p.m. on August 14, 1987.
  • Involvement of NBI Agents
    • Job Reyes, accompanied by three NBI agents and a photographer, returned to his office, opened the remaining packages in the agents’ presence, and uncovered additional dried marijuana leaves concealed under cigars and within bundles labeled as books and gloves.
    • The agents inventoried and took custody of the box and its contents, signing a receipt on October 7, 1987.
  • Appellant’s Arrest and Laboratory Examination
    • Attempts to locate appellant followed; he was invited to the NBI on August 27, 1987, while claiming mail at the Manila Central Post Office.
    • The seized substance was submitted to the NBI Forensic Chemistry Section and certified as marijuana flowering tops.
  • Trial Proceedings
    • An Information was filed charging violation of RA 6425 (Dangerous Drugs Act).
    • Appellant assigned errors concerning (a) alleged illegal search and seizure, (b) violation of custodial rights, and (c) credibility of his explanation regarding ownership of the packages.

Issues:

  • Whether the trial court erred in admitting evidence allegedly obtained through an illegal search and seizure.
  • Whether appellant’s constitutional rights during custodial investigation were violated, warranting reversal of his conviction.
  • Whether the trial court erred in disregarding appellant’s explanation that the packages belonged to a German national acquaintance.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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