People vs Leangsiri

FACTS:
 Appellants were charged with violating RA 6425 for illegally possessing the drug heroin.
 Thai National, Leangsiri, was arrested in the arrival area of NAIA for bringing heroin to the
Philippines. He informed the authorities that he was about to deliver the drugs to four people in
Las Palmas Hotel located in Manila.
 He was allowed to check into Room 504 of the hotel. The suspects entered the room and was
subsequently arrested.
 One of the suspects claimed he was merely staying in Room 413 of the same hotel.
 The officers searched the said room and it yielded to a piece of paper in a telephone book
bearing Leangsiri’s name.
ISSUE: Whether or not the paper bearing Leangsiri’s name may be admitted as an evidence
HELD: No. Officers are only allowed to search those which are in the immediate control of the person
arrested. However, this is not an absolute rule as the plain view doctrine is its exception. Objects in the
plain view of the arresting officer who has the right to be in that position to have that view are subject
to seizure and may presented as evidence. In the case at bar, appellants were arrested in Room 504 of
the Las Palmas Hotel. The piece of paper bearing Leangsiris name was obtained through a warrantless
search of Room 413 of the same hotel, and found tucked within the pages of appellant Amidu’s
telephone and address book (not within immediate control). Clearly, the warrantless search is illegal and
the piece of paper bearing Leangsiris name cannot be admitted as evidence against appellants.