G.R. No. 6800 - People vs De los Reyes

This is an appeal from a Court of First Instance judgment in Manila, where the lower court convicted two appellants—Valeriano de los Reyes and Gabriela Esguerra—for violating section 31 of Act No. 1761.
Both appellants were originally sentenced to six months’ imprisonment and ordered to pay the action’s costs.

A few days before November 5, 1910, Gabriela Esguerra, a visitor from San Miguel de Mayumo and a friend of the de los Reyes family, visited Valeriano at his Manila residence.
On November 5, 1910, while Gabriela was still a guest, certain revenue officials went to Valeriano’s house to search for opium.
Valeriano refused the officials entry on the ground that they had no warrant or legal authority to search his premises.
After a brief conversation in which the officials asserted their authority, Valeriano allowed them to enter without physical resistance, and the search commenced.

During the search, while some officers were inside inspecting the different parts of the house, others remained outside to ensure that no one would leave the premises.
An officer outside observed Gabriela Esguerra throw a package from the kitchen window into the grass behind the house.
Upon recovery, the package was found to contain a considerable quantity of morphine, indicating possession and control by Gabriela.

It is conceded that at the time of the discovery, Valeriano de los Reyes was in the front part of the house, and Gabriela was in the kitchen (a room in the rear).
No direct evidence links Valeriano to any knowledge of the morphine’s presence; his only connection is the inference drawn from his initial denial to allow the search.
The trial court’s reasoning for convicting Valeriano rested solely on the argument that his refusal to allow the search implied knowledge of opium being present on the premises.

The decision references established legal principles and doctrines regarding the inviolability of a dwelling, notably the maxim “a man’s house is his castle.”
Jurisprudence and treatises such as those by Judge Cooley and commentaries from Spanish Penal Code treatises are cited to underline constitutional limits on searches.
The decision juxtaposes authorized searches (with proper warrants or in exigent circumstances) with unlawful entry, emphasizing federal and constitutional protections against arbitrary search and seizure.

Whether Valeriano’s mere refusal to permit the search can be used as sufficient evidence to infer that he had knowledge of the contraband on his premises.
Whether the absence of direct evidence connecting him to the morphine nullifies the inference drawn from his conduct.

Whether Gabriela Esguerra’s actions—specifically her possession and subsequent attempt to dispose of the package containing morphine—constitute the criminal act prohibited by section 31 of Act No. 1761.
The evidentiary basis for holding her in actual possession of the contraband, as opposed to merely being present in the house.

Whether the act of entering the premises without a proper search warrant infringes on the constitutional guarantee against unreasonable searches and seizures.
The extent to which the authorities may rely on statutory provisions and constitutional doctrines that protect the sanctity of a person’s home.