G.R. No. 85177 August 20, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MOISES MASPIL, JR. y WAYWAY and SALCEDO BAGKING y ALTAKI, defendants-appellants.

FACTS

Accused-appellants Moises Maspil, Jr. and Salcedo Bagking were convicted for illegal transportation of marijuana. On November 1, 1986, NARCOM operatives, acting on a tip, established a checkpoint in Sayangan, Atok, Benguet. At around 2:00 AM, they intercepted a Sarao jeep driven by Maspil with Bagking as a companion. Inspection revealed the vehicle contained sacks and tin cans loaded with dried marijuana leaves weighing over 115 kilograms. The appellants were arrested at the scene. Forensic examination confirmed the substances were marijuana.
The defense claimed the marijuana belonged to two passengers, including a certain Danny Buteng, who had loaded the items in Abatan, Buguias, for transport to Baguio City. The appellants asserted they were hired to transport dried fish earlier and were unaware the subsequent cargo contained marijuana, having been told it consisted of flowers for All Souls’ Day. They alleged the real owners alighted at a restaurant just before the checkpoint and escaped pursuit.

ISSUE

The primary issue is whether the warrantless arrest and search of the appellants and their vehicle were valid, and whether their guilt for illegal transportation of marijuana was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The warrantless arrest and search were valid as exceptions under Rule 113, Section 5(a) of the Rules of Court. The appellants were caught in flagrante delicto; the crime of illegal transportation was actually being committed in the presence of the law enforcement officers at the checkpoint. The vehicle was lawfully stopped and inspected based on credible information, leading to the immediate discovery of the contraband. The Court distinguished this case from People v. Aminnudin, where there was sufficient time to obtain a warrant. Here, the information lacked specific details on the vehicle or exact time, justifying the warrantless action.
Regarding the defense of lack of knowledge, the Court ruled that the prosecution satisfactorily discharged its burden of proof. The appellants admitted the marijuana was confiscated from their jeep while they were transporting it. Transportation is a malum prohibitum act, and the law does not require criminal intent. Possession and control of the vehicle containing the drugs established their liability. Their claim of being mere common carriers unaware of the cargo’s nature was unsubstantiated and could not overcome the evidence of their direct participation in the act of transport. Thus, guilt was proven beyond reasonable doubt.