PEOPLE OF THE PHILIPPINES vs. ANDRE MARTI.
- G.R. Number: G.R. No. 81561
- Promulgated: 1991-01-18
- Ponente: Bidin, J.
Doctrine
Constitutional protection against unreasonable searches and seizures protects persons (citizen or alien) from government interference in their person, residence, papers, and possessions.
Where there is no governmental involvement or interference, the constitutional guarantee against unreasonable searches and seizures does not apply against private parties.
Facts
Appellant was convicted by the Special Criminal Court of Manila (RTC Branch XLIX) for violation of provisions of Republic Act No. 6425 (Dangerous Drugs Act).
The prosecution summarized the facts of the case in its brief (summary text not reproduced in the numbered paragraphs provided).
Appellant contested the admissibility of evidence on the ground that the 1987 Constitution renders inadmissible any evidence obtained in violation of the constitutional prohibition against unreasonable searches and seizures, arguing this applies whether the evidence was obtained by police or private individuals.
The Court of Appeals (Third Division) affirmed the conviction; the judgment finding appellant guilty beyond reasonable doubt was AFFIRMED.
Issues
Whether the constitutional right against unreasonable searches and seizures may be invoked against private individuals when there is no governmental interference.
Whether evidence obtained by private individuals is inadmissible under the 1987 Constitution's prohibition against unreasonable searches and seizures.
Ruling
No. In the absence of governmental interference, the liberties guaranteed by the Constitution against unreasonable searches and seizures cannot be invoked against private individuals; the protection is against government action.
The conviction was affirmed; the judgment finding appellant guilty beyond reasonable doubt is AFFIRMED.
Keywords
G.R. No. 81561, PEOPLE OF THE PHILIPPINES v. ANDRE MARTI, violation of Section 21 (b), Article IV in relation to Section 4, Article 11 and Section 2 (e) (i), Article 1 of Republic Act 6425, as amended, Dangerous Drugs Act, unreasonable search and seizure, privacy of communication, Sec. 2 and 3, Art. III, Constitution, inadmissible in evidence, exclusionary rule, Mapp v. Ohio, Stonehill v. Diokno (20 SCRA 383 [1967]), warrant of arrest, probable cause, search warrant, marijuana flowering tops, custodial proceedings, appellant, violation, october, packages