People of the Philippines vs. Jerry Sapla y Guerrero a.k.a. Eric Salibad y Mallari, G.R.

No. 244045, June 16, 2020.

Facts: The accused-appellant in this case, Jerry Sapla y Guerrero a.k.a. Salibad y Mallari was
charged of violating Section 5, Article II of Republic Act No. (R.A.) 9165, otherwise known
as the “Comprehensive Dangerous Act of 2002.”
On January 10, 2014, authorities received information from an anonymous source via
the duty on guard. They then formed a group and went to the Talaca detachment. At
approximately 1:20 p.m. on the same day, at Talaca, Agbannawag, Tabuk City, Kalinga,
accused-appellant Sapla willfully, unlawfully, and knowingly had in his possession, control,
and custody four (4) bricks of marijuana leaves, a dangerous drug, with a total net weight of
3,953.11 grams and transport through a passenger jeepney with plate no. AYA 270 the said
marijuana without any appropriate government entity or agency's license, permit, or
authority. He was then apprehended by police at the Talaca checkpoint.
On January 9, 2017, an RTC Judge found accused-appellant Sapla guilty of violating
Section 5 of R.A. 9165. The court found him guilty beyond a reasonable doubt of the crime
charged and sentenced him to perpetual reclusion and a fine of five million pesos.
Angry, accused appellant Sapla filed an appeal with the Court of Appeals. The CA
dismissed accused-appellant Sapla's appeal and upheld the RTC's decision, with the
modification that he pays one million pesos rather than five million pesos. The judge
ruled that, while the search and seizure of accused-appellant Sapla was conducted
without a search warrant, it was lawful because it was a valid warrantless search of a
moving vehicle. The CA determined that the necessary requisite of probable cause was
met, justifying the warrantless search and seizure.
Issue: Whether or not the police officers conducted a valid search and seizure based solely on
an unverified tip relayed by an anonymous informant.
Ruling: The Supreme Court granted the Petition and reversed and set aside the Court
of Appeals' decision acquitting accused-appellant Sapla of the crime charged.
The Supreme Court issued the following decision on the matter: The Court finds that
the RTC and CA erred in holding that the authorities' search and seizure in the instant case
was a valid warrantless search of a moving vehicle. The vehicle, rather than a specific person,
is the target in this type of search. According to jurisprudence, "warrantless search and
seizure of moving vehicles are allowed in recognition of the impracticability of securing a
warrant under said circumstances as the vehicle can be quickly moved out of the locality or
jurisdiction in which the warrant may be sought. In such cases, however, peace officers are
limited to routine checks with only a visual inspection of the vehicle. A warrantless search
has been held to be valid only if the officers conducting the search have reasonable or
probable cause to believe that they will find the instrumentality or evidence prior to the
search.

pertaining to a crime, in the vehicle to be searched." The situation presented in this

case cannot be considered a moving vehicle search. The Court emphasized the right of the
people to be free from unreasonable searches and seizures, as stated in Article III, Section 2
of the 1987 Constitution:
Sec. 2. The right of the people to be secure in their persons, houses, papers, and effects against
unreasonable searches and seizures of whatever nature and for whatever purpose shall not be
granted except upon probable cause, which shall be determined personally by the judge after
examination under oath or affirmation of the complainant and any witnesses he may produce,
and specifically describing the place to be searched and the persons or things to be seized. The
information they received through the RPSB Hotline (via text message) from an anonymous
person, as readily admitted by the CA, was the singular circumstance that engendered
probable cause on the part of the police officers.
The Court has previously stated definitively that "law enforcers cannot act solely on the basis
of confidential or tipped information" in situations involving warrantless searches and
seizures. Whatever the source, a tip is still hearsay. In the absence of any other circumstance
that would raise suspicion, it is insufficient to constitute probable cause." In short, the tip was
not yet actionable for the purposes of effecting an arrest or conducting a search in the absence
of other circumstances that would confirm their suspicion coming to the knowledge of the
searching or arresting officer. As a result of the glaring lack of probable cause that justifies an
intrusive warrantless search and given that the police officers relied solely on an unverified
and anonymous tip, the warrantless search conducted on accused-appellant Sapla was an
invalid and unlawful search of a moving vehicle.