PEOPLE OF THE PHILIPPINES V.

MARTI
G.R. No. 81561, January 18, 1991

BIDIN, J.:

I. FACTS

On August 14, 1987, Andre Marti and his wife, Shirley Reyes, had four gift-wrapped
packages shipped to a supposed friend in Zurich, Switzerland via a shipping company called
“Manila Packing and Export Forwarders” owned by Job Reyes and his wife. Before
delivering Marti’s packages to the Bureau of Customs (BOC), Job Reyes, inspected such
packages as part of standard operating procedures. Inside, he found dried leaves and took
samples thereof to send to the Narcotics Section of the National Bureau of Investigation
(NBI). After confirming that the contents of all packages were dried marijuana leaves, the
NBI then located Marti. Thereafter, an Information was filed against Marti in violation of
Section 21(b), Article IV, Article II, and Section 2(e)(i) of Article I of R.A. 6425, otherwise
known as the Dangerous Drugs Act.

Marti appealed the decision of the trial courts alleging that his constitutional right against
illegal search and seizure (Article III, Sections 2-3, of the Constitution) were violated when
the court admitted the evidence gathered by Job Reyes.

II. ISSUE

Did the lower court erred in admitting the evidence seized by Job Reyes and consequently,
violated the constitutional right of Marti against illegal search and seizure?

III. RULING

The Court AFFIRMED the decision of the trial court.

Andre Marti is guilty beyond reasonable doubt of violating R.A. 6425, otherwise known as
the Dangerous Drugs Act. His constitutional rights were not violated.

IV. RATIO

In the absence of governmental interference, the liberties guaranteed by the Constitution

cannot be invoked against the State. The Bill of Rights is not meant to be invoked against acts
of private individuals. In this case, since it was Job Reyes, a private citizen, who reported the
evidence with his own prerogative and with no persuasion from any law enforcement
agencies, the evidence is then admissible.