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Updated 21st February 2025
People vs. Suzuki
A case concerning illegal possession of marijuana where the Supreme Court affirmed the conviction but modified the penalty from death to reclusion perpetua, highlighting important principles about airport security searches and constitutional rights against unreasonable searches and seizures.

Primary Holding

The Supreme Court held that routine airport security procedures constitute a valid exception to the constitutional protection against warrantless searches and seizures. Persons may lose this protection due to reduced privacy expectations associated with air travel. When these procedures reveal contraband, and the accused is caught in flagrante delicto, both the warrantless search and subsequent arrest are valid. However, in imposing penalties for drug possession, courts must apply the lesser of two indivisible penalties when there are no aggravating or mitigating circumstances.

Background

The case stems from an airport security check at Bacolod Airport where the defendant, a Japanese national, was found in possession of marijuana concealed in a box of "Bongbong's piaya." The case raises important questions about the constitutionality of airport security searches and the rights of individuals against unreasonable searches and seizures.

History

  • The case commenced on April 12, 1994, with the arrest of Hedishi Suzuki at the Bacolod Airport Terminal. On the same day, he was brought to the PASCOM office and subsequently to the prosecutor's office for inquest proceedings. He was then placed under the custody of C/Inspector Ernesto Alcantara at the NARCOM office.

  • Two days later, on April 14, 1994, Suzuki was transferred to the Bacolod City Jail. The case was then filed before the Regional Trial Court of Bacolod City as Criminal Case No. 94-16100. Upon arraignment, the appellant entered a plea of not guilty, and the trial proceeded with the prosecution presenting several key witnesses: P/Inspector Rea Abastillas Villavicencio, a forensic chemist; SPO1 Arturo Casugod Sr. and PO3 Rhodelin Poyugao from PASCOM; and SPO1 Gilbert Linda from NARCOM.

  • On December 7, 1994, RTC Branch 45 of Bacolod City rendered its judgment. The court found the accused guilty beyond reasonable doubt and imposed the death penalty, along with a fine of ₱10,000,000.00. The court also ordered the confiscation of 1,547.07 grams of marijuana seized from the accused.

  • Due to the death penalty imposed, the case was automatically elevated to the Supreme Court for review. After nearly nine years, on October 23, 2003, the Supreme Court rendered its final decision. While affirming the conviction, the Court modified the penalty from death to reclusion perpetua and reduced the fine to ₱1,000,000.00.

Facts

  • 1. In November 1993, the PNP Narcotics Command issued a directive to cover all domestic airport terminals due to prevalent drug trafficking.
  • 2. On April 12, 1994, Hedishi Suzuki entered the pre-departure area of Bacolod Airport Terminal for Manila-bound flight No. 132.
  • 3. At security, the metal detector was activated when Suzuki passed through with a box marked "Bongbong's piaya."
  • 4. Upon inspection, authorities found 18 small packs, 17 wrapped in aluminum foil, containing marijuana fruiting tops.
  • 5. The total weight of marijuana was 1.9 kilograms (1,900 grams).
  • 6. Suzuki claimed the box was given to him by a woman named Pinky as "pasalubong" from Bacolod City.

Arguments of the Petitioners

  • 1. In November 1993, the PNP Narcotics Command issued a directive to cover all domestic airport terminals due to prevalent drug trafficking.
  • 2. On April 12, 1994, Hedishi Suzuki entered the pre-departure area of Bacolod Airport Terminal for Manila-bound flight No. 132.
  • 3. At security, the metal detector was activated when Suzuki passed through with a box marked "Bongbong's piaya."
  • 4. Upon inspection, authorities found 18 small packs, 17 wrapped in aluminum foil, containing marijuana fruiting tops.
  • 5. The total weight of marijuana was 1.9 kilograms (1,900 grams).
  • 6. Suzuki claimed the box was given to him by a woman named Pinky as "pasalubong" from Bacolod City.

Arguments of the Respondents

  • 1. The search was valid under airport security procedures
  • 2. Defendant consented to the search
  • 3. Arrest was valid as defendant was caught in flagrante delicto
  • 4. Evidence was legally obtained

Issues

  • 1. The search was valid under airport security procedures
  • 2. Defendant consented to the search
  • 3. Arrest was valid as defendant was caught in flagrante delicto
  • 4. Evidence was legally obtained

Ruling

  • 1. The Supreme Court affirmed the conviction but modified the penalty, reducing it from death to reclusion perpetua and lowering the fine to ₱1,000,000.00. In its decision, the Court emphasized that PASCOM agents possessed the legal authority to conduct searches under Republic Act 6235 and various executive issuances. The Court noted that this authority stems from the legitimate need to secure airports against unlawful interference and criminal activities.
  • 2. The Court upheld the validity of the airport security search as a recognized exception to the warrant requirement. It explained that passengers inherently have reduced privacy expectations in air travel, and routine security procedures are reasonable given the gravity of safety interests involved in aviation security. The Court found particularly significant that Suzuki had validly consented to the search, as evidenced by his eventual acquiescence and verbal permission, saying "open, open" despite his initial reluctance.
  • 3. Regarding the warrantless arrest, the Court determined it was valid as Suzuki was caught in flagrante delicto when the prohibited drugs were discovered in his possession. The Court rejected Suzuki's claim of being framed up, noting that aside from his bare testimony, no evidence was presented to support this allegation. The Court applied the presumption of regularity in the performance of official duties, finding no clear proof of any improper motive on the part of the law enforcement officers.
  • 4. On the matter of penalty, the Court found that the trial court had imposed the wrong punishment. While the quantity of marijuana (1,547.70 grams) qualified for the penalty of reclusion perpetua to death under the law, the Court held that absent any aggravating or mitigating circumstances, the lesser penalty of reclusion perpetua should be imposed following Section 63 of the Revised Penal Code. The Court also exercised its discretion to reduce the fine, noting that while a monetary penalty is mandatory in drug cases, courts have the authority to fix any amount within the limits established by law.

Doctrines

  • 1. Airport Security Exception: Recognizes reduced privacy expectations in air travel and validates routine security procedures.
  • 2. Consent Search: Valid consent waives constitutional protection against warrantless searches.
  • 3. In Flagrante Delicto: Allows warrantless arrest when crime is committed in the presence of officers.
  • 4. Presumption of Regularity: Official acts of law enforcement are presumed regular absent clear evidence of irregularity.

Precedents Cited

  • 1. "Persons may lose the protection of the search and seizure clause by exposure of their persons or property to the public in a manner reflecting a lack of subjective expectation of privacy, which expectation society is prepared to recognize as reasonable. Such recognition is implicit in airport security procedures."

Statutory and Constitutional Provisions

  • 1. Section 8, Republic Act No. 6235 - Authority for airport searches
  • 2. Section 5(a), Rule 113, Rules of Criminal Procedure - Warrantless arrests
  • 3. Republic Act No. 6425 (Dangerous Drugs Act), as amended by R.A. No. 7659
  • 4. Section 63, Revised Penal Code - Application of indivisible penalties