Facts:

The case involves Rosa Aruta y Menguin, who was arrested and charged with violating Section 4, Article II of Republic Act No. 6425, also known as the Dangerous Drugs Act. The incident occurred on December 14, 1988, in Olongapo City, Philippines. The prosecution's case was primarily based on the testimonies of P/Lt. Ernesto Abello and P/Lt. Jose Domingo, officers of the Narcotics Command (NARCOM). They received a tip from an informant named Benjie that a woman known as "Aling Rosa" would arrive from Baguio City with a significant quantity of marijuana. On the day of the incident, the NARCOM team positioned themselves near the Philippine National Bank and the Caltex gasoline station to await her arrival.

At approximately 6:30 PM, a Victory Liner bus stopped, and Aruta disembarked carrying a traveling bag. The informant identified her, prompting the officers to approach and question her about the contents of her bag. Upon inspection, they discovered approximatel...

Facts:

1. Background of the Case:
   Accused-appellant Rosa Aruta y Menguin was charged with violating Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act) for transporting approximately 8.5 kilos of dried marijuana. She pleaded "not guilty" during arraignment.

2. Prosecution's Version:

   • On December 13, 1988, P/Lt. Ernesto Abello, Officer-in-Charge of the Narcotics Command (NARCOM) in Olongapo City, received a tip from an informant named "Benjie" that a certain "Aling Rosa" would be arriving from Baguio City on December 14, 1988, carrying a large volume of marijuana.
   • On December 14, 1988, a NARCOM team, including P/Lt. Abello and P/Lt. Jose Domingo, positioned themselves near the Philippine National Bank (PNB) building and a Caltex gasoline station in Olongapo City.
   • At around 6:30 PM, a Victory Liner bus arrived, and the informant pointed out "Aling Rosa" (later identified as Rosa Aruta) carrying a traveling bag.
   • The NARCOM agents approached her, introduced themselves, and asked about the contents of her bag. She handed over the bag, which was found to contain dried marijuana leaves.
   • Rosa Aruta was arrested, and the marijuana was later confirmed to be a prohibited drug by a forensic chemist.

3. Defense's Version:

   • Rosa Aruta claimed she was not carrying any illegal drugs. She testified that she had just come from watching a movie and was asked by an old woman to help carry a shoulder bag. While crossing the road, she was arrested by NARCOM agents.
   • She denied knowledge of the bag's contents and stated that no search warrant was shown to her.

4. Trial Court's Decision:

   • The Regional Trial Court of Olongapo City convicted Rosa Aruta of transporting marijuana and sentenced her to life imprisonment and a fine of P20,000.
   • The defense filed a "Demurrer to Evidence," arguing that the search and seizure were illegal, but the trial court denied it without ruling on the legality of the search.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Constitutional Guarantee Against Unreasonable Searches and Seizures:

   • The Constitution guarantees the right of individuals to be secure against unreasonable searches and seizures. A search must generally be conducted with a valid warrant issued by a judge based on probable cause.
   • Evidence obtained from an unconstitutional search is inadmissible under the "fruit of the poisonous tree" doctrine.

2. Exceptions to the Warrant Requirement:

   • The Court outlined exceptions to the warrant requirement, such as searches incidental to a lawful arrest, "plain view" doctrine, search of moving vehicles, consented searches, customs searches, stop and frisk, and exigent circumstances.
   • None of these exceptions applied to Rosa Aruta's case. She was not committing a crime in the presence of the officers, nor was there probable cause to justify a warrantless search.

3. Lack of Probable Cause:

   • The NARCOM agents relied solely on the informant's tip without corroborating evidence or observing suspicious behavior from Rosa Aruta.
   • The Court emphasized that probable cause must be based on reasonable grounds of suspicion supported by strong circumstances, which were absent in this case.

4. Invalidity of Consent:

   • The Court rejected the prosecution's argument that Rosa Aruta consented to the search by handing over her bag. Her lack of objection did not constitute voluntary consent, especially under coercive circumstances.

5. Failure to Secure a Search Warrant:

   • The NARCOM agents had sufficient time (over 24 hours) to secure a search warrant but failed to do so. The Court noted that the informant's tip provided enough details (e.g., the suspect's name, the vehicle, and the time of arrival) to justify a warrant application.

6. Exclusion of Evidence:

   • Since the search and seizure were unconstitutional, the marijuana seized could not be used as evidence against Rosa Aruta. The Court reiterated that the exclusionary rule is essential to enforce constitutional protections against unreasonable searches and seizures.

Conclusion:

The Supreme Court acquitted Rosa Aruta due to the prosecution's failure to prove her guilt beyond reasonable doubt. The warrantless search and seizure violated her constitutional rights, rendering the evidence inadmissible. The Court emphasized the importance of adhering to constitutional safeguards, even in cases involving illegal drugs.