G.R. No. 114396 February 19, 1997
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILLIAM ROBERT BURTON, accused-appellant.

FACTS

Accused-appellant William Robert Burton, a British national, was apprehended at the Ninoy Aquino International Airport on December 26, 1992, while attempting to depart for Sydney, Australia. An x-ray examination of his two pieces of luggage revealed suspicious dark areas. Upon further inspection, with Burton’s consent, authorities slashed open the bags and discovered twelve rectangular bricks and one square brick of a dark brown substance concealed within the sidings and false bottom. The total weight was 5.6 kilograms. Suspecting he was walking uneasily, investigators also checked his shoes and found four more blocks of the same material. Laboratory tests by the NBI and PNP Crime Laboratory confirmed the substance to be hashish, a prohibited derivative of marijuana.
Burton was charged with and convicted of attempting to transport a prohibited drug under the Dangerous Drugs Act. The trial court sentenced him to life imprisonment and a fine. On appeal, he denied criminal liability, claiming he was unaware the drugs were in his luggage and challenging the credibility of the apprehending officers.

ISSUE

The core issue is whether the accused-appellant’s defense of lack of knowledge (or animus furiandi) over the prohibited drugs found concealed in his luggage and shoes is a valid defense against the charge of attempting to transport dangerous drugs.

RULING

The Supreme Court affirmed the conviction. The legal logic is grounded in the nature of the offense as defined under Section 4 of Republic Act No. 6425 , which penalizes the act of transporting any prohibited drug. The Court ruled that the crime is malum prohibitum. As such, criminal liability attaches upon the mere commission of the act, irrespective of the offender’s intent or moral guilt. Good faith or lack of criminal intent is not a defense.
The Court found the prosecution evidence conclusive. The drugs were discovered hidden within the structural components of Burton’s own luggage and shoes—items completely within his control and possession. This manner of concealment logically contradicts any claim of innocent lack of knowledge. The defense of frame-up was rejected for failing to present clear and convincing evidence of any ill motive on the part of the law enforcement officers, who were presumed to have performed their duties regularly. Consequently, the element of animus furiandi or criminal intent, while not required for the commission of the crime itself, was sufficiently established by the circumstances of the case, negating his professed ignorance. The penalty of life imprisonment was upheld.