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Evardo vs. People

VIRGILIO EVARDO Y LOPENA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

G.R. No. 234317 | 2021-05-10

THIRD DIVISION
 
D E C I S I O N
 
LEONEN, J.:
 
A warrantless, intrusive search of a moving vehicle cannot be premised solely on an initial tip.[1] It must be founded on probable cause where "[t]here must be a confluence of several suspicious circumstances."[2] As the cause for the search, each such circumstance must occur before the search is commenced. Further, they must each be independently suspicious. Thus, when law enforcers are predisposed to perceive guilt—as when specific persons are the targets of checkpoints, patrols, and similar operations—their subjective perception...