In People v. Del Mundo, the Supreme Court affirmed that knowledge of ownership is not a requirement for conviction in cases involving the transportation of illegal drugs. The Court emphasized that the crime of transporting illegal drugs is malum prohibitum, meaning the act itself is prohibited by law regardless of the offender’s intent or knowledge. This ruling clarifies that merely transporting illegal drugs, even without awareness of the contents, is sufficient grounds for conviction, highlighting the strict liability imposed on those involved in drug trafficking.

When a Tricycle Ride Leads to a Drug Trafficking Charge

This case revolves around Florentino del Mundo, who was apprehended and charged with violating Section 4, Article II of Republic Act No. 6425, also known as the Dangerous Drugs Act of 1972. The accusation stemmed from an incident on November 20, 1997, in Barangay Real, Calatagan, Batangas, where Del Mundo was allegedly caught selling, distributing, and transporting two bricks of marijuana fruiting tops, weighing 1,720 grams. The police acted on information that Del Mundo was selling illegal drugs, leading to his arrest and the discovery of the marijuana in his tricycle.

During the trial, the prosecution presented testimonies from PO2 Ramon Ancheta, PO1 Romeo Jonson, and P/Sr. Insp. Mary Jean Geronimo. The policemen testified that they saw Del Mundo handing something to another person. As they approached, Del Mundo attempted to flee. A search of his tricycle revealed a package containing marijuana. Del Mundo denied the allegations, claiming that a passenger left the package in his tricycle. He said he fled because he feared for his life when two unidentified men approached with firearms aimed at him and his passenger.

The trial court found Del Mundo guilty, emphasizing that the marijuana was confiscated from his vehicle. The court also noted that the police officers had no ill motive to fabricate charges against Del Mundo. The trial court upheld the validity of the warrantless arrest and the seizure of the marijuana, leading to Del Mundo’s conviction and a sentence of reclusion perpetua, along with a fine of P500,000.00.

Del Mundo appealed, arguing that the prosecution failed to prove he owned the marijuana or that he knew he was transporting a prohibited drug. He claimed the police’s pursuit of the unidentified passenger suggested uncertainty about the real owner of the marijuana. He further argued that the search of his vehicle and seizure of the marijuana were illegal because they were conducted without a warrant. He also contested the legality of his arrest, stating it was based on his inclusion in a police order of battle without any proof presented.

The prosecution countered that under Section 4, Article II of R.A. 6425, the sale, distribution, or transportation of prohibited drugs is punishable, irrespective of ownership. The prosecution contended that Del Mundo’s flight justified his warrantless arrest, as it gave the police reasonable grounds to believe he was committing a crime. Consequently, the search of his tricycle was valid as it was incidental to a lawful arrest.

The Supreme Court affirmed the trial court’s decision, holding that proof of ownership is not necessary in illegal drug cases. The Court underscored that the crucial element is the act of selling, administering, delivering, or transporting the prohibited drugs. Citing People v. Tang Wai Lan, the Court stated:

Proof of ownership of the marijuana is not necessary in the prosecution of illegal drug cases… it is sufficient that such prohibited substance was found in accused-appellant’s tricycle at the time he was apprehended.

The Court dismissed Del Mundo’s defense that the package belonged to his passenger as a weak alibi. It highlighted that a bare denial is an intrinsically weak defense, especially when contradicted by the positive testimony of prosecution witnesses and physical evidence. The Court cited People v. Capillo:

Accused-appellant’s bare denial is an intrinsically weak defense. It is negative and self-serving evidence which has no weight in law.

The Court also addressed the issue of Del Mundo’s knowledge of the contents of the package. It clarified that lack of knowledge is not a valid defense because drug trafficking is malum prohibitum. Therefore, criminal intent is not a necessary element for conviction. This principle is crucial because it places the burden on the accused to prove they did not intend to possess the prohibited drug, as highlighted in People v. Baludda:

Lack of criminal intent and good faith are not exempting circumstances where the crime charged is malum prohibitum.

The Court found Del Mundo’s attempt to flee from the police indicative of his guilt. It argued that an innocent person would typically stay and assert their innocence, rather than fleeing. The Court cited People v. Baludda, drawing a parallel to Del Mundo’s case:

The wicked flee when no man pursueth; but the righteous are as bold as a lion.

The Court also upheld the validity of the warrantless arrest and subsequent search. It reasoned that Del Mundo’s flight and the police’s prior information provided reasonable grounds to believe he was involved in drug trafficking. This falls under the exception to the warrant requirement for arrests made when a crime is being committed or has just been committed, as emphasized in People v. Lising:

Under the given circumstances, the warrantless arrest of accused-appellant was valid since the policemen had reasonable grounds to believe that he was dealing or transporting prohibited drugs.

Even if the arrest was initially flawed, the Court noted that Del Mundo failed to object to it before entering his plea, thereby waiving his right to question its legality. The Court also addressed the warrantless search of the tricycle, citing the exception for moving vehicles. It emphasized that securing a warrant for a moving vehicle is impractical, as the vehicle can quickly move beyond the jurisdiction. The Court noted the distinct scent of marijuana emanating from the package, which justified the police’s opening and examination of the contents, citing Garcia v. Court of Appeals:

It is of judicial notice that marijuana has a distinct, sweet and unmistakable aroma very different from that of ordinary tobacco.

The Supreme Court’s decision in People v. Del Mundo reinforces the strict enforcement of drug laws in the Philippines. It underscores that the act of transporting illegal drugs is a serious offense, regardless of the offender’s knowledge or intent. This ruling serves as a deterrent to those who might be involved in drug trafficking, even unknowingly, and it empowers law enforcement to act swiftly in suspected drug-related activities.

FAQs

What was the key issue in this case?	The key issue was whether the accused could be convicted of transporting illegal drugs without proof of ownership or knowledge of the drugs. The Supreme Court ruled that ownership and knowledge are not required for conviction in cases involving transportation of illegal drugs.
What is malum prohibitum?	Malum prohibitum refers to acts that are prohibited by law, regardless of whether they are inherently immoral. In such cases, the intent or knowledge of the offender is not a necessary element for conviction.
Was the warrantless arrest legal?	Yes, the warrantless arrest was deemed legal because the police had reasonable grounds to believe the accused was committing a crime. His attempt to flee upon seeing the police officers, combined with prior information, justified the arrest.
Why was the warrantless search of the tricycle considered valid?	The warrantless search was valid under the exception for moving vehicles. It is not practical to secure a warrant for a vehicle that can quickly move out of the jurisdiction, especially when there is probable cause to believe it contains illegal drugs.
What is the significance of the accused’s flight from the police?	The accused’s flight was interpreted as an indication of guilt. The court noted that an innocent person would typically stay and assert their innocence, rather than fleeing the scene.
What evidence did the prosecution present?	The prosecution presented testimonies from the arresting police officers and the forensic chemist. The officers testified about the accused’s suspicious behavior, flight, and the discovery of marijuana in his tricycle. The chemist confirmed that the seized substance was indeed marijuana.
What was the accused’s defense?	The accused claimed that a passenger left the package in his tricycle and that he fled because he feared for his life when armed men approached. He denied any knowledge of the drugs and claimed he was merely a tricycle driver.
What penalty did the accused receive?	The accused was sentenced to reclusion perpetua (life imprisonment) and ordered to pay a fine of P500,000.00, as prescribed by the Dangerous Drugs Act for the offense of transporting illegal drugs.

The Del Mundo case serves as a significant reminder of the stringent measures taken by Philippine law to combat drug trafficking. The ruling emphasizes the importance of vigilance and the potential legal consequences, even in cases where an individual may not be fully aware of the illicit nature of the goods being transported.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines vs. Florentino Del Mundo, G.R. No. 138929, October 02, 2001