Esquillo v People G.R. No.

182010, August 25, 2010 Article III, Section 2 This a petition questioning the validity of the warrantless search conducted by the police against the petitioner. Facts: Police officers were assigned in Malibay, Pasay to conduct surveillance on a notorious snatcher named Ryan. It was during that time the police officers noticed the petitioner. The police saw the petitioner standing three meters away from them. They saw the latter place inside a yellow cigarette case a plastic sachet containing a white substance. They approached the petitioner and introduced themselves as police officer. Subsequently, they inquired regarding the sachet the petitioner placed inside the case. The petitioner acted suspiciously and even tried to flee. The police officers prevented her from doing so. They apprised the petitioner of her constitutional rights and then they confiscated the sachet. They marked the sachet with the initials SRE and took the petitioner to the police station. The petitioner contends against the police officers statement. The petitioner said that she was resting at home when policemen barged inside and asked her whether or not she knew a certain Ryan. She replied in the negative. Afterwards, she was forcibly taken to the police station and was detained there. During her detention, the police officers were claiming that there was shabu inside the wallet they seized from her. In fine, the petitioner was claiming that the evidence was planted. Issue: Whether or not the warrantless arrest was valid.

Held/Ratio: YES. The circumstances before the eventual arrest gave the police officers a reasonable belief that a search on her was warranted. The police officer saw IN PLAIN VIEW that the petitioner was placing a plastic sachet containing a white substance inside her cigarette case. Given the training of police officers, they would likely be drawn to curiosity and approach her to inquire regarding such matter. The petitioners reaction of attempting to flee after the police officer introduced his self gave more reason for the officer to check the petitioner. Warrantless searches are valid in these situations: a) consented searches, b) searches incident to a lawful arrest, c) searches of vessels and aircraft for violation of immigration, custom and drug laws, d) searches of moving vehicles, e) searches of automobiles at borders, f) the prohibited articles are in plain view, g) searches of buildings to enforce fire, sanitary and other regulations, h) stop and frisk situations.

In order to execute a valid warrantless search, the officer conducting the search must have a genuine reason to exist to warrant a belief that a person who manifests unusual suspicious conduct has weapons or contraband concealed about him. Stop-and-frisk situations have a dual purpose: a) the general interest of crime prevention and b) the interest of safety and self-preservation.