FACTS:

During the trial, SUSAN raised several constitutional violations regarding the search and seizure. She argued that her constitutional rights were violated because the search was conducted without a warrant and without probable cause. She also claimed that the strip search went beyond the permissible limits and was not incidental to a lawful arrest. SUSAN further asserted that she was subjected to custodial investigation without counsel present. She also contested the admissibility of a medical report that was used as evidence against her, arguing that it was not offered in court nor testified on by the doctor. In addition, she questioned the applicability of the ruling in People v. Johnson, asserting that the case should have been decided based on the principles in Katz v. United States, which emphasizes the protection of people rather than places.

The trial court found SUSAN guilty of illegal possession of drugs based on the evidence presented, including the medical report. SUSAN then appealed the decision, disputing the alleged errors committed by the trial court. The OSG supported her conviction, arguing that the warrantless search was justified as incidental to a lawful arrest and that the drugs were seized pursuant to airport security procedures.

However, the Supreme Court affirmed SUSAN's conviction, stating that the warrantless search and seizure, as well as the arrest, did not violate her constitutional rights. The Court applied the exceptions to the interdiction against warrantless searches and seizures, emphasizing that the search of a person's body is permissible under certain circumstances. The Court also upheld the admissibility of the medical report, noting that SUSAN's conviction was not solely based on it. Moreover, the Court rejected SUSAN's argument regarding the application of People v. Johnson, ultimately upholding the decision and recommending a reduction in the imposed fine.

ISSUES:

1. Whether the search conducted on SUSAN was incidental to a lawful arrest.

2. Whether the scope of a search pursuant to airport security procedure is confined only to search for weapons under the "Terry search" doctrine.

3. Whether the ruling in People v. Johnson is applicable to the instant case.

4. Whether the packs of methamphetamine hydrochloride seized during a routine frisk at the airport are admissible in evidence against the accused.

5. Whether the subsequent warrantless arrest of the accused was justified.

6. Whether there was a violation of the accused's right to counsel during custodial investigation.

7. Whether the admission of the medical report violated the hearsay rule.

RULING:

1. The search conducted on SUSAN was not incidental to a lawful arrest.

2. The scope of a search pursuant to airport security procedure is not confined only to search for weapons under the "Terry search" doctrine.

3. The ruling in People v. Johnson is applicable to the instant case.

4. The packs of methamphetamine hydrochloride seized during the routine frisk at the airport are admissible in evidence against the accused. The Court held that the search and seizure were acquired legitimately pursuant to airport security procedures, which society is prepared to recognize as reasonable. The increased security measures at airports, in response to concerns over airplane hijacking and terrorism, justify the minimal intrusiveness of such searches. Furthermore, passengers are notified that ordinary constitutional protections against warrantless searches and seizures do not apply to routine airport procedures.

5. The subsequent warrantless arrest of the accused was justified. The Court held that the accused was caught flagrante delicto, as the discovery and recovery of shabu in her person provide probable cause for her arrest without a warrant.

6. There was no violation of the accused's right to counsel during custodial investigation as there was no evidence presented that a custodial investigation took place after the accused's arrest. Furthermore, no statement was taken from the accused during her detention and used as evidence against her.

7. The admission of the medical report was erroneous as it was not properly identified. However, even without the medical report, the accused's conviction will stand as it was not the basis for the court's finding of guilt.

PRINCIPLES:

• The interdiction against warrantless searches and seizures is not absolute.

• Recognized exceptions to the prohibition on warrantless searches and seizures include search of moving vehicles, seizure in plain view, customs searches, waiver or consented searches, stop and frisk situations (Terry search), and search incidental to a lawful arrest.

• A search is not incidental to a lawful arrest if the search precedes the arrest or if the purpose of the search is to ascertain whether a crime is being committed.

• Airport security procedures allow for searches of passengers and their hand-carried luggage for prohibited materials or substances.

• Consent to be searched may be given by a passenger when the metal detector alarms.

• The ruling in People v. Johnson, which involves similar facts and issues, is applicable to the case at hand.

• Persons may lose the protection of the search and seizure clause if they expose their persons or property to the public in a manner reflecting a lack of subjective expectation of privacy.

• Routine airport security procedures, including searches and seizures, are reasonable given the minimal intrusiveness, gravity of safety interests, and reduced privacy expectations associated with airline travel.

• The principle of stare decisis et non quieta movere requires adherence to precedents and mandates not to unsettle established principles of law.

• A person may be lawfully arrested without a warrant when the arresting officer has personal knowledge or probable cause to believe that the person to be arrested has committed, is committing, or is attempting to commit an offense.

• The right to counsel attaches upon the start of a custodial investigation and prohibits interrogation without full warnings of constitutional rights.

• The hearsay rule applies to the admission of evidence and requires proper identification of the document.