Title
Dabon vs. People
Case
G.R. No. 208775
Decision Date
Jan 22, 2018
Police searched Dabon's residence for drugs but violated procedural rules by not allowing him or his family to witness the search. The Supreme Court ruled the evidence inadmissible, acquitting Dabon due to the unconstitutional search.
A

Case Summary (G.R. No. 208775)

Facts Concerning Surveillance, Warrant, and Execution

PNP–CIDG operatives conducted surveillance and test-buys that led to the issuance of Search Warrant No. 15 for petitioner’s residence for alleged violations of Sections 11 and 12, Article II of R.A. No. 9165. On July 26, 2003, CIDG officers executed the warrant at a two‑storey apartment unit where Dabon resided. The operatives asked the named community and official witnesses to attend. During the search the officers located Dumaluan in the living room and Dabon in a bedroom. Police handed Dabon a copy of the search warrant and proceeded to search the kitchen, living area and bedroom.

Items Seized, Inventory, and Laboratory Examination

Officers recovered alleged drug paraphernalia in the kitchen and living room; detection and searches of the bedroom uncovered three plastic sachets allegedly containing shabu and assorted paraphernalia hidden within clothes in a drawer. SPO1 Triste inventoried the seized items and placed them in evidence bags in the presence of certain witnesses. A PNP forensic chemical officer (P/Insp. David Tan) performed chemical and confirmatory tests on the seized items, yielding results positive for methylamphetamine hydrochloride. Criminal informations were thereafter filed charging Dabon with violations of Sections 11 and 12, Article II of R.A. No. 9165; an information for Section 12 was also filed against Dumaluan.

Defense Assertions Regarding Manner of Search

Dabon’s defense asserted that he and other household members were not permitted to witness the search; they claimed they were ordered to sit in the living room while other household members were allegedly locked in another room. Dabon contended that he was surprised and awakened by officers who entered the bedroom, and he challenged the admissibility of the seized items on the ground that the search did not comply with statutory safeguards.

RTC Disposition and Sentencing

The RTC found the search valid, upheld the presumption of regularity in police performance, and convicted Dabon beyond reasonable doubt for violations of Sections 11 and 12 of R.A. No. 9165. The court imposed the applicable indeterminate sentences and fines, ordered turnover of the narcotics and paraphernalia to the PDEA for disposition/destruction, and returned the cellphone and cash to the accused upon motion. The RTC denied Dabon’s motion for reconsideration.

Court of Appeals Ruling

The CA affirmed the RTC decision. The CA reasoned, inter alia, that Dabon had waived his right to question his arrest by failing to raise the issue before arraignment, and in any event that alleged procedural defects did not negate the fact that drugs and paraphernalia were seized at Dabon’s residence. The CA denied reconsideration and the matter was brought to the Supreme Court on certiorari under Rule 45.

Issue Presented to the Supreme Court

The Supreme Court framed the controlling issue as whether the evidence obtained against Dabon was admissible given the manner of the search and the asserted noncompliance with statutory and constitutional safeguards.

Constitutional and Procedural Legal Framework

The Supreme Court applied the 1987 Constitution’s protection against unreasonable searches and seizures, quoting the constitutional provision protecting persons, houses, papers, and effects and requiring that warrants issue only upon probable cause and that they particularly describe the place to be searched and the things to be seized. The Court further invoked Rule 126 Section 8 of the Rules of Court, which mandates that searches of a house, room, or premises be made in the presence of the lawful occupant or any member of his family, or, in their absence, in the presence of two witnesses of sufficient age and discretion residing in the same locality. The exclusionary rule (that evidence obtained in violation of constitutional guarantees is inadmissible) was applied consistent with the constitutional and Rule-based protections.

Analysis of Compliance with the Two‑Witness Requirement

The Court examined testimonial evidence, specifically the testimony of PO2 Datoy and the confirmation by Brgy. Kagawad Angalot, which established that when the bedroom was searched Dabon and his wife were outside the room (in the sala and comfort room, respectively) and were not permitted to witness the search. Testimony showed that only Brgy. Kagawad Angalot was present during the bedroom search; the claimed presence of SK Chairman Angalot was refuted by the cited testimonies. Given the hierarchy established by Section 8, Rule 126, the lawful occupants were present and yet were not allowed to witness the search, and the two‑witness alternative was not satisfied. The Court relied on prior precedents emphasizing the mandatory nature of this requirement and the consequence that noncompliance renders evidence inadmissible.

Application of the Exclusionary Rule and Treatment of Procedural Waiver Arguments

The Court applied the exclusionary rule, holding that failure to comply with the safeguards of Section 8 made the search unreasonable and the seized items inadmissible for any purpose. The Court considered and rejected arguments that Dabon had waived his right to object by failing to file a timely motion to suppress. Citing prior decisions, the Court explained that procedural rules cannot diminish constitutional rights, and that waiver of constitutional protections must be clear, knowing, and intelligent. The Court noted that Dabon had raised the objection in his omnibus motion for reconsideration in the trial court and therefore found that the lack of proce

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