G.R. No. 148117 . March 22, 2007
MABINI EPIE, JR. and RODRIGO PALASI, Petitioners, vs. THE HON. NELSONIDA T. ULAT-MARREDO, Presiding Judge, Regional Trial Court, Branch 10, La Trinidad, Benguet and THE PEOPLE OF THE PHILIPPINES, Respondents.

FACTS

Petitioners Mabini Epie, Jr. and Rodrigo Palasi were charged with violating Section 68 of the Revised Forestry Code for the unauthorized possession and transport of 870 board feet of Benguet pine lumber. The prosecution evidence established that on September 6, 1998, a confidential informant alerted SPO2 Alberto Ngina that a jeepney with a specific plate number was loaded with lumber at a location in Atok, Benguet. The police immediately set up a checkpoint in Acop, Tublay.
Upon spotting the described jeepney heading towards La Trinidad at around 4:00 p.m., the police flagged it down. The vehicle did not stop, prompting a chase until it was intercepted in Shilan, La Trinidad. A search revealed pieces of Benguet pine lumber concealed under assorted vegetables. The petitioners, who were among the occupants, failed to present any permit from the DENR authorizing the transport of the lumber.

ISSUE

Whether the warrantless search and seizure of the lumber from the moving vehicle is valid, rendering the evidence admissible.

RULING

The Supreme Court affirmed the validity of the warrantless search and the admissibility of the seized lumber. While the Constitution guarantees the right against unreasonable searches and seizures, recognized exceptions exist, including the search of a moving vehicle. For such a warrantless search to be valid, there must be probable cause.
Probable cause in this context means a reasonable belief, based on factual circumstances, that an offense has been committed and that the vehicle contains evidence thereof. Here, probable cause was sufficiently established. The police acted on specific information from a confidential informant regarding a vehicle carrying illegal lumber. The vehicle’s subsequent refusal to stop when flagged down, necessitating a chase, reinforced the reasonable suspicion of illicit activity. This conduct, an attempt to evade inspection, provided the police with ample justification to believe a law was being violated.
The Court cited the precedent in People v. Vinecarao, where a vehicle’s flight after noticing a checkpoint constituted probable cause for a warrantless search. The police, therefore, acted within a recognized exception to the warrant requirement. Consequently, the trial court did not commit grave abuse of discretion in denying the motion to suppress the evidence, and the seized lumber is admissible against the petitioners. The petition was denied.