Case Digest (G.R. No. 244045)
Facts:
People of the Philippines v. Jerry Sapla y Guerrero a.k.a. Eric Salibad y Mallari, G.R. No. 244045, June 16, 2020, Supreme Court En Banc, Caguioa, J., writing for the Court.The prosecution (the People) charged Jerry Sapla y Guerrero (accused‑appellant Sapla) by Information dated 14 January 2014 with violation of Section 5, Article II of R.A. No. 9165 (illegal transportation of dangerous drugs), alleging that on 10 January 2014 he transported four bricks of marijuana weighing a total of 3,956.311 grams aboard a passenger jeepney, Plate No. AYA 270. Sapla was arrested on 15 January 2014, arraigned on 29 January 2014, pleaded not guilty, and trial followed.
The prosecution presented police witnesses who testified that an anonymous informant phoned and later texted the Regional Public Safety Battalion (RPSB) identifying a male wearing a collared white shirt with green stripes, red ball cap, carrying a blue sack and riding the jeepney bound for Roxas, Isabela; a checkpoint was set up at Talaca and the jeepney was flagged down about 1:20 p.m., where officers confronted Sapla, asked him to open the blue sack, and discovered the four bricks. The seized items were photographed, inventoried and submitted for chemistry examination, which tested positive for marijuana. Sapla denied ownership at trial and offered a different account.
On 9 January 2017 the Regional Trial Court (RTC), Branch 25, Tabuk City, convicted Sapla and sentenced him to reclusion perpetua and imposed a fine; the RTC found corpus delicti and admitted the seized marijuana. Sapla appealed to the Court of Appeals (CA) Second Division which, in its Decision of 24 April 2018, denied the appeal and affirmed the RTC with modifications—imposing life imprisonment and a P1,000,000 fine—holding the search a lawful warrantless search of a moving vehicle supported by probable cause.
Sapla then filed an appeal to the Supreme Court (notice of appeal dated April 24, 2018). The Supreme Court En Banc, with Associate Justice Caguioa as ponente, took up the case and delivered judgment on 16 June 2020. Separate concurring an...(Subscriber-Only)
Issues:
- Was the warrantless search and seizure of the blue sack and its contents valid under the Constitution and applicable jurisprudence?
- If the search was challenged as consented, was any purported consent by the accused valid, knowing, and voluntary?
- If the search and seizure were invalid, are the seized drug specimens nevertheless admissible or must they be exclud...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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