GR 90640; (March, 1994) (Digest)
G.R. No. 90640 March 29, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BONIFACIO BARROS, accused-appellant.
FACTS
Bonifacio Barros was charged with violating Section 4 of R.A. No. 6425 (Dangerous Drugs Act) for allegedly transporting about four kilos of dried marijuana on a Dangwa bus on September 6, 1987. The prosecution’s evidence established that two PC soldiers, M/Sgt. Francis Yag-as and S/Sgt. James Ayan, saw Barros board the bus at Chackchakan, Bontoc, carrying a carton which he placed under his seat. At a checkpoint in Sabangan, C2C Fernando Bongyao inspected the carton, found marijuana, and, after the bus conductor identified Barros, invited Barros for questioning. Barros initially denied ownership but later admitted it after the conductor’s identification. He was medically examined, where he admitted to smoking marijuana, and was taken to Tadian, where he signed a seizure receipt. Laboratory tests confirmed the substance was marijuana. The defense consisted of Barros’s denial of ownership, claiming he was framed and that his confession was extracted under threat and intimidation without being informed of his rights.
ISSUE
Whether the trial court deprived the accused of his right to due process by: (1) ignoring the manifest absence of a mandatory warrant in the arrest and search; (2) admitting confessions extracted under intimidating circumstances; and (3) misappreciating facts.
RULING
The Supreme Court REVERSED and SET ASIDE the decision of the Regional Trial Court and ACQUITTED Bonifacio Barros. The Court held that the warrantless search and seizure were unconstitutional. The police officers had no personal knowledge that Barros was committing a crime when they searched the carton; the search was based merely on a tip or suspicion, which does not justify a warrantless search under the circumstances. The evidence obtained (the marijuana) was therefore inadmissible as “fruit of the poisonous tree.” The Court found it unnecessary to rule on the admissibility of the confessions, as the trial court did not rely on them for conviction. Without the illegally seized marijuana, the prosecution’s evidence was insufficient to prove guilt beyond reasonable doubt.