### Facts
– On January 14, 2014, Jerry Sapla y Guerrero a.k.a. Eric Salibad y Mallari (“Sapla”) was charged for violating Section 5, Article II of R.A. No. 9165, for unlawfully transporting four (4) bricks of marijuana with a total net weight of 3,956.311 grams.
– The prosecution’s evidence detailed that on January 10, 2014, police officers received a tip from an anonymous caller about someone transporting marijuana from Kalinga to the Province of Isabela. Acting on the tip, a team was organized, and a checkpoint was established. Later, the officers received a text message further describing the suspect.
– A passenger jeepney where Sapla was riding was stopped at the checkpoint. Sapla was identified as fitting the description given by the anonymous informant. Upon opening the sack in front of him, as requested by the officers, four (4) bricks of suspected marijuana were discovered, leading to his arrest.
– Sapla presented an alibi, asserting he had no knowledge about the marijuana found, suggesting the illicit items were planted.
### Procedural Posture
– The Regional Trial Court (RTC) convicted Sapla of the crime charged, affirming the legality of the warrantless search, and sentenced him to reclusion perpetua and a fine of P5,000,000.00.
– The Court of Appeals (CA) affirmed the RTC’s Decision with modifications, sentencing Sapla to life imprisonment and a fine of P1,000,000.00.
– Sapla appealed to the Supreme Court, challenging the CA’s decision, particularly the legality of the warrantless search that led to his arrest and the seizure of the marijuana.
### Issues
1. Whether the warrantless search and seizure conducted on Sapla was valid.
2. Whether the evidence obtained from the warrantless search is admissible.
### Court’s Decision
– The Supreme Court ruled in favor of Sapla, setting aside the CA’s decision. The Court held the warrantless search and seizure as invalid, emphasizing the absence of probable cause and violation of Sapla’s rights against unreasonable searches and seizures.
– Since the search was deemed unlawful, the evidence obtained thereby— the marijuana bricks—was inadmissible. Consequently, Sapla was acquitted due to the prosecution’s failure to prove his guilt beyond reasonable doubt, considering the inadmissibility of the primary evidence against him.
### Doctrine
– The Supreme Court reiterated the doctrine that evidence obtained from an unreasonable search and seizure is inadmissible for any purpose in any proceeding. It emphasized the protection provided by the Constitution against unreasonable searches and seizures, underscoring that the eradication of illegal drugs cannot justify the violation of constitutional rights.
### Class Notes
– **Probable Cause for Warrantless Search:** Requires a reasonable ground of suspicion supported by circumstances sufficiently strong to warrant a cautious person’s belief that the accused is guilty of the offense.
– **Exclusionary Rule (Fruit of the Poisonous Tree Doctrine):** Evidence obtained from an unlawful search and seizure is inadmissible in evidence against the accused.
### Historical Background
– The case represents a significant judicial examination of law enforcement practices in the Philippines, particularly the balance between effective crime prevention and upholding constitutional rights. The decision underscores the Supreme Court’s steadfast commitment to protect individual rights even amidst the state’s aggressive campaign against illegal drugs.
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