GR 138539; (January, 2003) (Digest)
G.R. Nos. 138539-40. January 21, 2003.
PEOPLE OF THE PHILIPPINES, appellee, vs. ANTONIO C. ESTELLA, appellant.
FACTS
Antonio C. Estella was charged with illegal possession of dangerous drugs (marijuana) under RA 6425, as amended. A search warrant was issued for his residence at Purok Yakal, Barangay Baloganon, Masinloc, Zambales. On November 20, 1996, a police team, accompanied by the Barangay Captain, proceeded to enforce the warrant. The prosecution’s version states that the team saw appellant sitting near a hut owned by his brother and rented by appellant’s live-in partner. They approached him, served the warrant, and appellant allegedly surrendered two cans of marijuana from inside the hut. A subsequent search yielded more marijuana bricks and a firearm. The defense version claims appellant was about 70 meters away from his actual house when apprehended. He identified his real house to the police, but they instead searched a nearby hut occupied by other persons. Appellant denied owning the hut or surrendering any marijuana. The Regional Trial Court convicted appellant of illegal drug possession but acquitted him of illegal possession of firearms. Appellant appealed.
ISSUE
The pivotal issue is the legality of the search conducted in the hut where the marijuana was seized, and consequently, the admissibility of the evidence obtained.
RULING
The Supreme Court granted the appeal and reversed the conviction. The search was declared illegal, and the evidence obtained was inadmissible. The Constitution bars evidence gathered in violation of the right against unreasonable search and seizure. The prosecution failed to prove that the hut searched was owned, controlled, or used by appellant for residential or any other purpose. The search warrant described appellant’s residence, but the evidence did not establish that the hut was his house. Testimonies indicated the hut belonged to appellant’s brother and was rented by another person. The barangay captain’s action in leading the police to the hut did not conclusively prove appellant’s ownership or control. Since the hut was not shown to be under appellant’s control, he had no standing to object to the search, but more critically, the prosecution could not prove he possessed the items found therein. Without the illegally seized evidence, the prosecution’s case collapsed. Appellant’s guilt was not proven beyond reasonable doubt, and he was acquitted.