Title
People vs. Suzuki
Case
G.R. No. 120670
Decision Date
Oct 23, 2003
Japanese national convicted for illegal possession of 1.9 kg marijuana at Bacolod Airport; Supreme Court affirmed conviction, modified penalty to reclusion perpetua, reduced fine to P1,000,000.00.

Case Summary (G.R. No. 120670)

Factual Background

On April 12, 1994, airport security’s walk‐through metal detector signaled a metallic presence in a box marked “Bongbong’s piaya” carried by appellant. PASCOM personnel asked him to open it; he initially hesitated but ultimately consented, uttering “open.” Inside were eighteen foil‐wrapped packs of dried marijuana fruiting tops totaling 1.9 kg. Appellant attempted to flee but was apprehended, informed of his rights, and the seized material was submitted for laboratory confirmation.

Procedural Posture

The Regional Trial Court (RTC), Branch 45, Bacolod City, convicted appellant of illegal possession of marijuana under Section 8, Article II, R.A. No. 6425, sentencing him to death and a ₱10 million fine. Under R.A. No. 7659, the case proceeded to automatic review before the Supreme Court.

Issues Presented

Appellant challenged:

  1. PASCOM’s authority to open and search the box.
  2. Validity of his consent to search.
  3. Constitutionality of warrantless search and seizure.
  4. Misapplication of plain‐view and incidental‐to‐arrest doctrines.
  5. Sufficiency of proof of animus possidendi.
  6. Alleged frame‐up by co‐accused and officers.
  7. Excessiveness of the death penalty and fine.

Search Authority under R.A. No. 6235 and LOI No. 399

The Court held PASCOM’s security function—created by LOI 399 and a 1978 MOU—empowers it to inspect hand‐carried luggage. Section 8, R.A. No. 6235 authorizes carriers to open suspicious packages “to help the authorities.” PASCOM, as airport security implementing arm, lawfully operated under this grant and security manuals to conduct the search.

Consent to Search

Testimony established appellant’s voluntary consent. Despite initial reluctance, he verbally assented (“open”) after explanation. The RTC’s credibility finding—that appellant understood English and knowingly waived his right to object—was affirmed.

Flagrante Delicto and Arrest

Discovery of marijuana during a lawful, consented search rendered appellant caught in flagrante delicto. His warrantless arrest under Section 5(a), Rule 113, Rules of Criminal Procedure, was valid as the offense was committed in the officers’ presence.

Admissibility of Seized Evidence

The marijuana was admissible. The Court rejected reliance on plain‐view and incidental‐arrest exceptions but upheld admissibility based on valid consent and lawful search procedures.

Frame-Up Allegations

Appellant’s claim of a conspiracy involving Takeshi Koketsu and certain officers lacked any supporting evidence or witness testimony. In absence of clear and

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