### Facts:
In the evening of June 28, 1989, police officers Sgt. Victorino Noceja and Pat. Alex de Castro were on routine patrol in Barangay Sampalucan, Pagsanjan, Laguna, when they noticed a passenger jeep covered with kakawati leaves, which aroused their suspicion. They stopped the jeep, driven by Rudy Caballes y Taiño, and upon inspection, found it loaded with aluminum/galvanized conductor wires owned by the National Power Corporation (NPC). Caballes claimed the wires were from Cavinti and were loaded by masked men. He was taken to the police station and jailed for seven days.
At the arraignment for theft, Caballes pleaded not guilty, claiming to be part of an entrapment operation informed to his NARCOM superior, intended to catch individuals transporting stolen wires. However, his defense was not credited by the trial court, which on April 27, 1993, found him guilty of theft. This verdict was affirmed by the Court of Appeals, albeit with some modifications to the penalties and deletion of damages since the stolen materials were recovered.
Caballes appealed to the Supreme Court, challenging the warrantless search and seizure of his vehicle and the evidence obtained therefrom and questioning the reliability of his supposed entrapment operation participation.
### Issues:
1. Whether the warrantless search of Caballes’ vehicle and the seizure of items therein violated his constitutional rights.
2. Whether the Court of Appeals erred in rejecting Caballes’ entrapment operation defense.
3. Whether the prosecution failed to establish Caballes’ guilt beyond reasonable doubt.
### Court’s Decision:
The Supreme Court reversed the Court of Appeals’ decision, acquitting Caballes. The Court found that the police officers did not have probable cause for a warrantless search of Caballes’ vehicle as mere covered appearance of the vehicle with kakawati leaves did not justify suspicion. The search did not fall under any of the recognized exceptions to the warrant requirement. The consent to the search was not freely and voluntarily given but was instead implied from a passive compliance which cannot be considered as consent under constitutional guarantees against unreasonable searches and seizures. As the evidence against Caballes was obtained through an unlawful search, it was inadmissible, rendering the prosecution unable to establish his guilt beyond reasonable doubt.
### Doctrine:
The case reinforced the principle that warrantless searches and seizures are generally unreasonable unless they fall within the recognized exceptions. Moreover, consent to search, to be valid, must be voluntary, specific, and unequivocally conveyed. Evidence acquired through a violation of the constitutional right against unreasonable searches and seizures is inadmissible.
### Class Notes:
– The constitutional protection against unreasonable searches and seizures applies regardless of the presence or absence of a warrant.
– Probable cause is necessary for warrantless searches except in specific, narrowly defined circumstances.
– Consent to a search must be unequivocal, intelligently given, and free from duress or coercion.
– Evidence obtained from an unconstitutional search and seizure is inadmissible in court (“fruit of the poisonous tree doctrine”).
### Historical Background:
This case exemplifies the Philippine legal system’s adherence to constitutional rights against unreasonable searches and seizures, reflecting the principles established in both the local and international jurisprudence on human rights and due process of law. It underscores the balance the judiciary maintains between law enforcement objectives and safeguarding individual liberties.
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