Scribd Logo
Upload

Welcome to Scribd!

  • People VS Sapla

    Uploaded by

    IRISH PARAN
    46 views1 page
    The Supreme Court reversed the conviction of Jerry Sapla for drug trafficking. Peace officers received an anonymous tip about Sapla transporting marijuana but a tip alone is not sufficient to constitute probable cause to conduct an extensive warrantless search. For a warrantless search of a moving vehicle to be valid, officers must have reasonable cause to believe evidence of a crime will be found before the search. Here, officers had no reason to suspect Sapla of any criminal activity based on observation, so the extensive search and seizure of evidence was invalid. Without this evidence, the prosecution had no basis to support a conviction. The Supreme Court found errors in the lower courts' judgments.

    Original Description:

    Original Title

    4. PEOPLE VS SAPLA

    Copyright

    © © All Rights Reserved

    Available Formats

    DOCX, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Report this Document
    The Supreme Court reversed the conviction of Jerry Sapla for drug trafficking. Peace officers received an anonymous tip about Sapla transporting marijuana but a tip alone is not sufficient to constitute probable cause to conduct an extensive warrantless search. For a warrantless search of a moving vehicle to be valid, officers must have reasonable cause to believe evidence of a crime will be found before the search. Here, officers had no reason to suspect Sapla of any criminal activity based on observation, so the extensive search and seizure of evidence was invalid. Without this evidence, the prosecution had no basis to support a conviction. The Supreme Court found errors in the lower courts' judgments.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as docx, pdf, or txt
    46 views1 page

    People VS Sapla

    Uploaded by

    IRISH PARAN
    The Supreme Court reversed the conviction of Jerry Sapla for drug trafficking. Peace officers received an anonymous tip about Sapla transporting marijuana but a tip alone is not sufficient to constitute probable cause to conduct an extensive warrantless search. For a warrantless search of a moving vehicle to be valid, officers must have reasonable cause to believe evidence of a crime will be found before the search. Here, officers had no reason to suspect Sapla of any criminal activity based on observation, so the extensive search and seizure of evidence was invalid. Without this evidence, the prosecution had no basis to support a conviction. The Supreme Court found errors in the lower courts' judgments.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as docx, pdf, or txt
    of 1

    PEOPLE OF THE PHILIPPINES, 

    Petitioner, v. JERRY SAPLA Y GUERRERO a.k.a ERIC


    MALLARI SALIBAD Respondent. CAGUIOA, J.:

    NATURE OF THE CASE: an appeal to the decision of the Court of Appeals.

    DOCTRINE: If the process of gathering evidence against the accused is tainted by a violation of
    the accused rights against unreasonable searches and seizures, which is a most cherished and
    protected right under the Bill of Rights, the evidence procured must be excluded, inevitably
    leading to the accused acquittal. (Exclusionary Rule)

    A tip is still hearsay no matter how reliable it may be. It is not sufficient to constitute a probable
    cause.

    FACTS: The accused Jerry Sapla in the information filed that he was found around 1:20 in the
    afternoon on January 10, 2014 at Talaca, Agbannawag, Tabuk City, Kalinga having in
    possession the four bricks of Marijuana Leaves and transporting such without permit or authority
    from any appropriate agency through a passenger jeepney with plate no. AYA 270.

    In the trial, the prosecution established that on January 10, 2014 at 11:30 in the morning, the
    RPSB office received a phone call from a concerned citizen that a certain male individual would
    be transporting a marijuana from Kalinga to Isabela which PO2 Mabiasan relayed to its deputy
    commander PSI Ngoslab and PO3 Labbutan coordinated as well with PDEA. Another text
    message was received by the RPSB hotline which states the shirt of Jerry Sapla, the blue sack
    and along with its vehicle and plate number. Due to this, a joint check point was strategically
    organized at Talaca Command Post. It was then that, Sapla was arrested and was informed of
    his cause of his arrest in Ilocano dialect.

    On January 9, 2017, the RTC Judge convicted accused for violation of Section 5 of RA 9165
    and found guilty thereof. He was charged to suffer penalty of Reclusion Perpetua and pay fine
    of Five Million Pesos. The accused appeal to the Court of Appeals but it was denied. The CA
    found that the search and seizure was without warrant, the same was lawful as it was a valid
    warrantless search of a moving vehicle. Hence, this petition.

    Issue: Whether the mere reception of a text message from anonymous person to suffice to
    create a probable cause that enables the authorities to conduct an extensive and intrusive
    search without warrant.

    Held: No. The Court already held that 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 a probable cause. The court finds error in the RTC and CA’s holding that
    the search and seizure conducted by the authorities is a valid warrantless search of a moving
    vehicle. In this type of search, the vehicle is the target and not a specific person. According to
    jurisprudence, warrantless search and seizure of moving vehicles are allowed in recognition of
    impracticability of securing warrant under the said circumstances as the vehicle can be quickly
    moved out of locality or jurisdiction in which the warrant may be sought. Peace officers,
    however, are limited to routine checks where the examination of the vehicle is limited to visual
    inspection. Such warrantless search has been held to be valid only as long as the officers
    conducting the search have reasonable or probable cause to believe before the search that they
    will find the instrumentality or evidence pertaining to a crime. A tip is not considered as probable
    cause to do an extensive search. The court explained that “no overt physical act could probably
    attributed to accused as to rouse suspicion in the minds of the arresting officers that he had just
    committed, was committing or was about to commit a crime. Since there was no valid search
    and seizure that took place. Hence, the gathered evidence or the Marijuana cannot be admitted
    to court then the prosecution with no left evidence to support conviction of the accused Sapla.

    The Supreme Court reversed the decision of the Court of Appeals.

    You might also like