People v Marti

G. R. No. 81561

Facts:

Accused went to the Manila Packing and Export Forwarder to deliver 4 packages to a friend from Zurich. The proprietress ask if she could inspect the package but the accused refuse and assured her that it only contains cigar, books and glove for his friend thus the proprietress did not insist and place the package in a box. Before the package will be forwarded to the Bureau of Custom and Bureau of Post a proprietor standard procedure inspect the package of the accused, upon opening of the said box containing the package a strange scent was smelled by the proprietor thus through his curiosity he squeeze one of the package and was able to obtain its  content. He forwarded the sample that he obtain from the package to the NBI for laboratory test and he was interview by the NBI agents and said he still has the package of the accused. In the presence of the NBI agent he opened the said package and saw bundles of dried leaves which was latter identified as marijuana contained in 4 package. The NBI filed a charge against the accused for the violation of the Dangerous Drugs Act which he was found guilty by the lower court. The accused now contends that the evidence obtained from the package was illegal as it was a violation of his constitutional right against Illegal searches and seizures and Privacy of communication thus is inadmissible as evidence in court.

Issue:

Whether or not the accused constitutional right against Illegal searches and seizure and Privacy of Communication had been violated.

Ruling:

No, the SC said that in a line of cases which evidence had been obtain through the violation of the said constitutional right against Illegal searches and seizures and Privacy of communication it can be noted that said evidence were obtain by the agent of the state through its law enforcers and other authorize government agency. Thus the case at bar peculiar one since the evidence acquired was procured by a private individual acting in his private capacity. The court said 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. Thus, it could only be invoked against the State to whom the restraint against arbitrary and unreasonable exercise of power is imposed. In the case at bar the search is made at the initiative of the proprietor of a private establishment for its own and private purposes, as in the case at bar, and without the intervention of police authorities, the right against unreasonable search and seizure cannot be invoked for only the act of private individual, not the law enforcers, is involved. In sum, the protection against unreasonable searches and seizures cannot be extended to acts committed by private individuals so as to bring it within the ambit of alleged unlawful intrusion by the government.