[01] PEOPLE V.
SAPLA ISSUE w/ RATIO
G.R. No. 244045 | June 16, 2020 | Caguioa, J.
Topic: Moving vehicle; Criminal Procedure
SUMMARY
The police received an anonymous tip that a man would be transporting marijuana from Kalinga
to Isabela. On the basis of this tip alone, the police set up a checkpoint and apprehended Sapla.
The Court held that a tip alone does not amount to probable cause, rendering the extensive
search of a moving vehicle invalid, and the evidence obtained therefrom inadmissible as
evidence. Sapla was acquitted.
DOCTRINE
● Law enforcers cannot act solely on the basis of confidential or tipped information. A tip is
still hearsay, no matter how reliable it may be. It is not sufficient to constitute probable
cause in the absence of any other circumstance that will arouse suspicion.
● Exclusive reliance on an unverified, anonymous tip cannot engender probable cause that
permits a warrantless search of a moving vehicle that goes beyond a visual search. There
must be overt acts and other circumstances personally observed by the police that
engender suspicion. The police should not adopt the suspicion initiated by another person.
FACTS
● At 11:30 AM of January 10, 2014, the police of Tabuk City, Kalinga received an anonymous
phone call from a concerned citizen who informed the police that a certain male would be
transporting marijuana that same day from Kalinga into Isabela.
● Later at 1:00 PM, the duty guard received another anonymous tip through a text message
sent to the police hotline. According to the text message, the subject male who would be
transporting marijuana would be wearing a collared white shirt with green stripes, a red ball
cap, and would be carrying a blue sack on board a passenger jeepney with plate number
AYA 270 bound for Isabela. The duty guard relayed the message to the police, who then
organized a checkpoint on the basis of these tips.
● At 1:20 PM, the jeepney arrived at the checkpoint. The police flagged it down and asked the
driver to park on the side of the road.
o Version of the prosecution: The police then saw Sapla, who matched the description
from the tip, seated at the rear side of the vehicle with a blue sack in front of him. They
asked him if the sack was his, and Sapla answered yes. They then asked Sapla to open
the sack. Sapla complied, and the police found four bricks of marijuana leaves inside
the sack. Sapla was subsequently arrested.
o Version of Sapla: The police searched the passengers’ baggages and found marijuana
inside a sack. They were looking for a person who wore fatigue pants. Of the three
passengers wearing fatigue pants, the police singled him out and identified him as the
owner of the marijuana. But the marijuana was not his, for he did not even have any
baggage at the time.
● Laboratory tests later confirmed that the items seized were marijuana, and both the RTC
and the CA convicted Sapla for violating Section 5 of RA 9165. The CA found that although
the search conducted was warrantless, it was a valid warrantless search of a moving
vehicle because the essential requisite of probable cause was present.
Was the search and seizure valid? NO.
● When warrantless search is valid: As a general rule, a search and seizure operation is
reasonable only when the court issues a search warrant. There are, however, instances
when searches are reasonable even without a search warrant:
o 1. warrantless search incidental to a lawful arrest
o 2. seizure of evidence in plain view
o 3. search of a moving vehicle
o 4. consented warrantless search
o 5. customs search
o 6. stop and frisk
o 7. exigent and emergency circumstances
● When warrantless search of a moving vehicle is valid: Warrantless searches of moving
vehicles are allowed because of the impracticability of securing a warrant under the
circumstances as the vehicle can be quickly moved out of the locality or jurisdiction in
which the warrant may be sought. However, police officers are limited to routine
checks/visual inspection only in these cases (not extensive searches).
● When warrantless, extensive search of a moving vehicle is valid: This is only allowed only
when the police make it upon probable cause, which means that facts and circumstances
exist which could lead a reasonably discreet and prudent man to believe that an offense
has been committed and that evidence or instrumentality pertaining to the crime is in the
vehicle to be searched.
Was this case one of a search of a moving vehicle? NO.
● In search of a moving vehicle, the vehicle is the target and not a specific person. It is clear
from the facts that the target of this search was not the jeepney but the person who
matched the description in the anonymous tip.
● To extend to such breadth the scope of searches on moving vehicles would open the
floodgates to unbridled warrantless searches which can be conducted by the mere
expedient of waiting for the target person to ride a motor vehicle, setting up a check point
along the route of that vehicle, and then stopping such vehicle when it arrives at the
checkpoint in order to search the target person.
● Even if characterized as a search of a moving vehicle, the seizure is still not valid. When a
vehicle is stopped for an extensive search, the warrantless search is valid only as long as
the officers conducting the search have reasonable or probable cause to believe before the
search that they will find instrumentality or evidence pertaining to a crime
● Sheer unverified information from an anonymous informant does not engender probable
cause on the part of the authorities that warrants an extensive and intrusive search of a
moving vehicle.
Did the anonymous tip constitute probable cause to justify the extensive search of a moving
vehicle? NO.
● A tip is hearsay, not matter how reliable it may be. It is not sufficient to constitute probable
cause in the absence of any other circumstance that will arouse suspicion.
● Exclusive reliance on an unverified, anonymous tip cannot engender probable cause that
permits a warrantless search of a moving vehicle that goes beyond a visual search. There
must be overt acts and other circumstances personally observed by the police that
engender suspicion. The police should not adopt the suspicion initiated by another person.
● Adopting a contrary rule would set an extremely dangerous and perilous precedent wherein,
on the sheer basis of an unverified information passed along by an alleged informant, the
 authorities are given the unbridled license to undertake extensive and highly intrusive
searches, even in the absence of any overt circumstance that engenders a reasonable
belief that an illegal activity is afoot, which would be a violation of the constitutional
guarantee against unreasonable search and seizure.
If this case does not fall under search of a moving vehicle, do the other instances of reasonable
warrantless searches apply? NO.
● This is clearly not a search made incidental to a lawful arrest, seizure of evidence in plain
view, customs search, or search made under exigent and emergency circumstances. This is
also not a stop and frisk search, which is limited to a protective search of outer clothing for
weapons or contraband.
● The finding of the CA that this was a consented warrantless search is invalid. The Court
indulges every reasonable presumption against waiver of fundamental rights (such as that
against unreasonable searches) and acquiescence in the loss of fundamental rights is not
to be presumed. The fact that a person failed to object to a search does not amount to
permission to the search. Mere passive conformity to the warrantless search is only an
implied acquiescence which does not amount to consent.
May the confiscated marijuana bricks be used as evidence against Sapla? NO.
● According to Article III, Section 3 (2) of the Constitution, any evidence obtained in violation
of the right against unreasonable searches and seizures shall be inadmissible for any
purpose in any proceeding. This is known as the exclusionary rule: evidence obtained and
confiscated on the occasion of such unreasonable searches and seizures is deemed
tainted and should be excluded for being the proverbial fruit of a poisonous tree.

RULING
Sapla’s appeal is granted. The decision of the CA is reversed and set aside. Sapla is acquitted
and is ordered immediately released.