Case Summary (G.R. No. 81561)
Issues on Appeal
- Whether the trial court erred in admitting evidence allegedly obtained through unconstitutional search and seizure.
- Whether appellant’s constitutional rights during custodial proceedings were violated.
- Whether the trial court should have credited appellant’s explanation of the parcels’ provenance.
Search and Seizure Analysis
The exclusionary rule under the 1987 Constitution (Art. III, Secs. 2–3) bars evidence procured through unlawful government searches. However, the Supreme Court distinguishes searches by private individuals from state action. A private‐actor inspection, uncoerced and independent of police authority, does not invoke constitutional restraints against unreasonable search and seizure. Jurisprudence (Villanueva v. Querubin; Burdeau v. McDowell; Barnes v. US) confirms that constitutional guarantees protect individuals from government intrusion, not private‐party inspections. Here, Job Reyes’s private search, part of his business practice, preceded and justified NBI involvement; the agents merely observed and took custody of already exposed contraband. Their presence did not convert a lawful private inspection into a constitutional violation. Accordingly, the evidence was admissible.
Custodial Proceedings and Miranda Rights
Appellant contended his rights under Article III were ignored during NBI interrogation. The records, however, show that appellant invoked his right to remain silent and refused to give a written statement. NBI officers testified, without contradiction, that appellant was duly informed of his rights. In the absence of evidence proving otherwise, the presumption of regular performance by law enforcement stands, and no unconstitutional custodial interrogation occurred.
Credibility of Appellant’s Explanation
Appellant’s claim that an unnamed German national instructed him to ship the parcels and paid him ₱2,000 lacks credibility. The Supreme Court applied the presumption of ownership (Rule 131, Sec. 5[j]) and weighed appellant’s self‐serving denial against the improbability of entrusting valuable contraband to a half‐hour acquaintance. Furthe
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Procedural Posture
- Appeal from a conviction rendered by the Special Criminal Court of Manila (RTC, Branch XLIX) finding appellant guilty of violating Section 21(b), Article IV in relation to Section 4, Article 11 and Section 2(e)(i), Article I of Republic Act No. 6425, as amended (Dangerous Drugs Act).
- Information filed after NBI laboratory examination certified seized dried leaves as marijuana flowering tops.
- Appellant raised three assignments of error: (1) illegal search and seizure; (2) violation of custodial investigation rights; (3) failure to credit appellant’s explanation of ownership.
- G.R. No. 81561; Decision by Justice Bidin; Third Division; January 18, 1991.
Facts
- On August 14, 1987 (10:00–11:00 a.m.), appellant and his common‐law wife, Shirley Reyes, delivered four gift‐wrapped packages to “Manila, Packing and Export Forwarders” in Ermita, Manila.
- Appellant declared the contents as books, cigars, and gloves to be shipped to “Walter Fierz, Mattacketr II, 8052 Zurich, Switzerland”; refused proprietary inspection when requested by Anita Reyes.
- Packages placed inside a 1′ × 2′ corrugated box with Styrofoam padding, sealed with masking tape, then held pending final inspection before customs or postal release.
- Job Reyes (proprietor’s husband) opened the box as standard procedure, detected a peculiar odor, extracted samples from one bundle, and brought them to the NBI Narcotics Section at about 1:30 p.m.
- NBI agents accompanied Job Reyes back to the forwarding agency; in their presence, he opened all parcels, uncovering cellophane wrappers and bricks of dried marijuana leaves beneath cigars.
- NBI agents inventoried the box and contents, signed a receipt, then attempted to locate appellant; appellant was invited to the Central Post Office on August 27, 1987, and detained for questioning.
- Forensic Chemistry Section confirmed