How do you reconcile the case of People vs. Marti and Zulueta vs. CA takinginto consideration the years when they were decided? What is the implication of the Zulueta case on the principle that the Bill of Rights only applies as against theState?
It is a well-
settled rule in Constitutional Law that evidence obtained in violation of a person’s
right of privacy of communication and correspondence and his right against unreasonablesearched and seizure are inadmissible as evidence for any purpose in any proceeding.
More commonly known as the “fruit of the poisonous tree doctrine”, this rule simply
suggests that things that have been illegally seized cannot legally be used to hold a caseagainst a person in court.But we have here two cases with almost the same facts and circumstances but with twocontrasting rulings. In both cases, two private individuals invoked their constitutional rightto privacy of communication and correspondence and right against unreasonable searchesand seizures but only the contention of one was sustained by the Court and the other wasdenied.In the legal system of the Philippines, there is a legal principle called
literally means “to stand by that which is decided.”
Under this principle are two otherprinciples, the first one is that
are to respect the precedents established by priordecisions. And the second one is that judges cannot overturn its own precedents unlessthere is a strong reason to do so of it is contrary to principle. In the case at bar, the Courthas adhered to the second principle of
in overturning their previous decision inthe Marti case. As what can be gleaned from the factual antecedents of both cases, theevidence seized in the Marti case was found incidentally by the owner carrier whileperforming standard operation procedures in his business, while the evidence submitted in