Title
Caballes y Taino vs. Court of Appeals
Case
G.R. No. 136292
Decision Date
Jan 15, 2002
A jeep covered with leaves was flagged down by police, leading to the discovery of stolen wires. The Supreme Court ruled the warrantless search unconstitutional, excluding evidence and acquitting the driver due to lack of probable cause.
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Case Summary (G.R. No. 136292)

Conviction and Sentencing

  • The Regional Trial Court of Santa Cruz, Laguna convicted Rudy Caballes of theft for stealing aluminum cable conductors valued at P55,244.45 from the National Power Corporation.
  • The court sentenced him to imprisonment and ordered him to indemnify the complainant.
  • The Court of Appeals affirmed the conviction but modified the penalty and deleted the award for damages.

Warrantless Search and Seizure

  • Caballes challenged the validity of the warrantless search conducted by police officers and the admissibility of the evidence obtained.
  • Warrantless searches of moving vehicles are permissible at borders or checkpoints but require probable cause if conducted within the interior of the territory.
  • The police flagged down Caballes' vehicle due to its unusual covering with kakawati leaves, which they deemed suspicious.

Lack of Probable Cause

  • The court held that the mere appearance of the vehicle did not constitute probable cause for a warrantless search.
  • There was no evidence of a confidential report or tip-off regarding stolen items in Caballes' vehicle, which is often necessary to establish probable cause.
  • The cable wires were not in plain view, as they were covered and not immediately observable.

Plain View Doctrine

  • The plain view doctrine allows for the seizure of items that are clearly visible without a search warrant.
  • In this case, the cable wires were not exposed; they were inside sacks and covered by leaves, thus not qualifying for seizure under this doctrine.

Consent to Search

  • The police claimed that Caballes consented to the search, but the court found this assertion lacking in clarity and evidence.
  • Consent must be voluntary, unequivocal, and shown by clear and convincing evidence, which was not established in this case.
  • The manner in which the police approached the search suggested coercion rather than a request for consent.

Judicial Precedents on Consent

  • The court referenced previous cases where consent was deemed valid, emphasizing that clear and specific requests for consent were made.
  • In contrast, the police officers in Caballes' case did not clearly ask for permission; instead, they informed him they would search the vehicle.

Passive Submission Not Implied Consent

  • Caballes' passive submission to the search was not interpreted as consent.
  • The court highlighted that a peaceful s...continue reading

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