Case Summary (G.R. No. L-34959)
Petitioner
Franklin B. Vaporoso and Joelren B. Tulilik, charged with Illegal Possession of Dangerous Drugs under Section 11, Article II of Republic Act No. 9165.
Respondent
People of the Philippines, represented by the Office of the Solicitor General.
Key Dates
- August 25–26, 2013: Incident, arrest, searches, and laboratory examination of seized substances.
- October 9, 2013: Arraignment; petitioners pleaded not guilty.
- December 14, 2015: RTC Decision convicting petitioners.
- November 17, 2017: CA Decision affirming conviction.
- February 26, 2018: CA Resolution denying reconsideration.
- June 3, 2019: Supreme Court Decision granting petition.
Applicable Law
- 1987 Philippine Constitution, Article III, Section 3(2) (Exclusionary Rule)
- Revised Rules on Criminal Procedure, Rule 113, Section 5 (Warrantless Arrest)
- Revised Rules on Criminal Procedure, Rule 126, Section 13 (Search Incident to Lawful Arrest)
- Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002)
Facts
- PO2 Torculas observed two men on a motorcycle holding a lady’s bag believed taken from a parked vehicle. The riders fled when ordered to stop.
- Vehicle owner Dombase corroborated that her belongings were stolen by the men. Torculas pursued and called for backup.
- After a six-hour stakeout in a secluded area, petitioners were arrested at around 1:00 AM, and their bags were recovered.
- Initial cursory search yielded only personal effects; a more thorough search at the police station produced nine sachets of white crystalline substance.
- Inventory and photo documentation were conducted in the presence of DOJ and media representatives. Laboratory analysis confirmed methamphetamine hydrochloride.
RTC Ruling
- Found petitioners guilty beyond reasonable doubt of Illegal Possession of Dangerous Drugs.
- Held that the stationhouse search was incidental to a valid warrantless arrest (continuous custody, no lapse of substantial time, administrative processing incomplete).
- Imposed an indeterminate sentence of 14 to 17 years’ imprisonment and a fine of ₱300,000 each.
CA Ruling
- Affirmed the RTC decision in toto.
- Cited PNP Handbook Rule 19 permitting searches to screen contraband before detention.
- Upheld chain of custody compliance per parties’ stipulation.
- Noted petitioners failed to present evidence for denial or frame-up defenses.
Issues
Whether the warrantless searches, especially the second search at the police station, were valid as searches incidental to a lawful arrest and whether the resultant drug evidence was admissible.
Supreme Court’s Ruling
Validity of Arrest
- Under Rule 113, Section 5, a “hot pursuit” warrantless arrest is lawful when personal knowledge and immediacy exist.
- PO2 Torculas personally witnessed suspicious conduct, received victim’s narration, pursued petitioners continuously, and arrested them within a limited timeframe.
- Arrest was valid; petitioners’ failure to challenge it waives jurisdictional defects but not the admissibility of evidence obtained via illegal search.
Validity of Searches
- First body search at place of arrest was lawful and incidental to arrest.
Case Syllabus (G.R. No. L-34959)
Facts of the Case
- Two separate Informations (CrC 430-2013 and CrC 431-2013) were filed on August 27, 2013, charging petitioners with Illegal Possession of Dangerous Drugs under Section 11, Article II of RA 9165.
- On August 25, 2013 at around 7:00 PM, Police Officer 2 Alexander D. Torculas observed two men on a motorcycle—later identified as petitioners—holding a lady’s bag, which appeared to have been taken from a parked vehicle along National Highway, Barangay Salvacion, Panabo City.
- When PO2 Torculas signaled them to stop, petitioners fled. The vehicle owner, Narcisa Dombase, informed the officer that her car window had been broken and belongings stolen.
- PO2 Torculas pursued petitioners into a secluded area on Bangoy Street, called for backup, and conducted a stake-out with PO1 Ryan B. Malibago and Intel operatives.
- At approximately 1:00 AM the following day, petitioners emerged and attempted to flee but were apprehended. A cursory body search recovered only Dombase’s belongings.
- At the Panabo Police Station, a “more thorough” search yielded five plastic sachets of white crystalline substance from Vaporoso and four from Tulilik. Items were marked, photographed, and inventoried in the presence of a DOJ representative, a barangay kagawad, and a media representative.
- On August 26, 2013, the Provincial Crime Laboratory confirmed the substance as methamphetamine hydrochloride (shabu). The seized sachets were delivered to court on December 18, 2013.
- Petitioners pleaded not guilty on October 9, 2013. Trial was dispensed with by stipulation of facts on September 10, 2015, and memoranda were submitted thereafter.
RTC Decision
- In a Decision dated December 14, 2015, the Regional Trial Court of Panabo City, Branch 34, found petitioners guilty beyond reasonable doubt of Illegal Possession of Dangerous Drugs.
- Each was sentenced to an indeterminate term of 14 to 17 y