G.R. No. L-41686, November 17, 1980.
PEOPLE OF THE PHILIPPINES, petitioner, vs. COURT OF FIRST INSTANCE OF RIZAL, BRANCH IX, QUEZON CITY, presided by HON. ULPIANO SARMIENTO, JESSIE HOPE and MONINA MEDINA, respondents.

FACTS

This case originated from a warrantless search and seizure conducted by agents of the Regional Anti-Smuggling Action Center (RASAC). The agents intercepted a car owned by respondent TSgt. Jessie Hope, which contained eleven sealed boxes of wristwatches and bracelets. Respondents Hope and his companion, Monina Medina, were subsequently charged with violating the Tariff and Customs Code. The trial court issued orders declaring the warrantless apprehension, search, and seizure as violative of Section 3, Article IV of the Constitution , rendering the seized items and related photographs inadmissible as evidence. The prosecution challenged these orders via certiorari.
A pivotal development occurred within the administrative proceedings of the Bureau of Customs. The Customs authorities, in a separate decision, declared the seized articles not subject to forfeiture. They found that the goods had been purchased in good faith by a claimant, Antonio del Rosario, under a genuine invoice from a trading firm. Consequently, the Customs authorities ordered the release of the goods to del Rosario upon payment of duties and taxes and ordered Hope’s car released to him, finding he was merely asked to transport the boxes back to Manila and had no involvement in their importation or purchase.

ISSUE

The primary issue is whether the warrantless search and seizure of the boxes from Hope’s car is valid under an exception to the constitutional warrant requirement. A corollary issue is the effect of the Customs authorities’ administrative decision declaring the goods lawfully acquired and not subject to forfeiture on the pending criminal case.

RULING

In his separate opinion, Justice Teehankee dissented from the majority’s validation of the warrantless search and seizure, while concurring with the directive for the prosecution to reassess the evidence. On the first aspect, he argued the search did not fall under any recognized exception, such as the “search of a moving vehicle” doctrine from Carroll v. United States. That exception requires probable cause plus exigent circumstances, primarily the vehicle’s mobility and the impracticability of securing a warrant. Justice Teehankee rigorously scrutinized the facts, noting the RASAC agents had conducted surveillance for about a week. This ample time and opportunity to secure a warrant negated any claim of exigency, making the warrantless search constitutionally unreasonable.
On the second aspect, Justice Teehankee held that the Customs authorities’ administrative decision rendered the question of the evidence’s admissibility moot. Since the very agency tasked with enforcing customs laws had definitively found the goods were lawfully purchased in good faith and ordered their release, their admission in the criminal trial could not logically establish the respondents’ criminal liability for smuggling. The administrative finding that Hope was merely a transporter without culpability directly undermined the prosecution’s basis. Therefore, he concluded that simple fairness and justice demanded the prosecution move for the dismissal of the criminal case, aligning with the Court’s directive for a prompt reassessment of the evidence.