People VS Marti
People VS Marti
People VS Marti
Facts:
On August 14, 1987, the appellant and his common-law wife, Shirley Reyes went to
Manila Packaging and Export Forwarders to send packages to Zurich, Switzerland. It
was received by Anita Reyes and ask if she could inspect the packages. Shirley refused
and eventually convinced Anita to seal the package making it ready for shipment.
Before being sent out for delivery, Job Reyes, husband of Anita and proprietor of the
courier company, conducted an inspection of the package as part of standard operating
procedures. Upon opening the package, he noticed a suspicious odor which made him
took sample of the substance he found inside. He reported this to the NBI and invited
agents to his office to inspect the package. In the presence of the NBI agents, Job
Reyes opened the suspicious package and found dried-marijuana leaves inside. A case
was filed against Andre Marti in violation of R.A. 6425 and was found guilty by the court
a quo. Andre filed an appeal in the Supreme Court claiming that his constitutional right
of privacy was violated and that the evidence acquired from his package was
inadmissible as evidence against him.
Issue:
Ruling:
The Supreme Court held based on the speech of Commissioner Bernas that the Bill of
Rights governs the relationship between the individual and the state.
The constitutional proscription against unlawful searches and seizures therefore applies
as a restraint directed only against the government and its agencies tasked with the
enforcement of the law. It is not meant to be invoked against acts of private individuals.
It will be recalled that Mr Job Reyes was the one who opened the box in the presence of
the NBI agents in his place of business. The mere presence of the NBI agents did not
convert the reasonable search effected by Mr. Reyes into a warrantless search and
siezure proscribed by the constitution. Merely to observe and look at that which is in
plain sight is not a search.
The judgement of conviction finding appeallant guilty beyond reasonable doubt of the
crime charged was AFFIRMED.