Constitutional Law: PEOPLE VS. TABAR


PEOPLE VS. TABAR

FACTS:
Respondent-accused was charged, together with her nephew, for violation of the Dangerous Drugs Act in an information which provided that:
 That on or about the 8th day of February 1989, at about 3:00 PM. in the City of Cebu, Philippines, and within the jurisdiction of this Honorable Court, the said accused, conniving and confederating together and mutually helping each other, with deliberate intent, did then and there sell and deliver, without authority of law, Three (3) sticks of marijuana cigarettes, a (sic) prohibited drugs, to a person who posted himself as a buyer, in Viol. of Sec. 4, Art. 11, of RA 6425, as amended, otherwise known as the Dangerous Act of 1972.
The accused were then convicted of the offense charged against them in the trial court.
On appeal, respondent presented her argument that the lower court erred in admitting the evidence against her when there wasn’t any search warrant. Therefore, violating the constitutional guarantee against unreasonable searches and seizures.

ISSUE: WON there was a violation against the constitutional guarantee of individuals against unreasonable searches and seizures.

RULING:
The second assigned error is without merit. The evidence for the prosecution discloses that the appellant placed the packs of marijuana sticks under the rolled pair of pants which she was then carrying at the time she hurriedly left her shanty after noticing the arrest of Rommel. When she was asked to spread it out, which she voluntary did, the package containing the packs of marijuana sticks were thus exposed in plain view to the member of the team. A crime was thus committed in the presence of the policemen. Pursuant to Section 5, Rule 113 and Section 12 Rule 126 of the Revised Rules of Court, she could lawfully be arrested and searched for anything which may be used as proof of the commission of an offense without the corresponding arrest and search warrants
Even assuming ex gratia argumenti that the seach and seizure were without a warrant, the appellant had effectively waived her constitutional right relative thereto by voluntarily submitting to the seach and seizure. In People vs. Malasugui, 20 this Court ruled:

When one voluntarily submits to a search and consent to have it made of his person or premises, he is precluded from later complaining thereof. The right to be secure from unreasonable seach may, like every right, be waived and such waiver may be made either expressly or impliedly.
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