Case Digest (G.R. No. 120915)
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...
Case Digest (G.R. No. 120915)
Facts:
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.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.
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.
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:
- Whether the NARCOM agents could have applied for a search warrant given the circumstances.
- Whether the warrantless search and seizure violated Rosa Aruta's constitutional rights.
- Whether the trial court erred in not finding that the prosecution's evidence was weak despite the defense's denial.
- Whether the warrantless search and seizure fell under any recognized exceptions to the warrant requirement.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
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.