Riley vs.

California

Fruit of a poisonous tree is a well-known legal doctrine that is usually utilized as a

defense to those accused of committing an offense whereas evidence that were seized from the
person concerned thereof were illegally obtained. Thus, this evidence and pieces of evidence are
inadmissible to any court or proceeding because the source it itself which is the tree itself was
tainted with irregularity, hence anything obtained from the source is tainted as well.

The same doctrine concerns the case of Riley v California, herein case, Officers pulled
over Riley for a traffic violation, which led to his arrest on weapon-related charges. Riley was
searched after his arrest and officers seized his cell phone from his pocket. Riley was convicted
after a trial where evidence seized from his phone was introduced in a shooting related charge. In
response, Riley appealed his conviction to the California state court of appeals. The court upheld
the trial court’s conviction. Another defendant, Wurie, had his flip phone seized incident to
arrest. Officers used the items seized in the phone to secure a search warrant to search Wurie’s
home. Thus the cases were consolidated by the Court because of the same action. Hence, The
underlying issue was whether or not the government conduct a warrantless search of the contents
of a cell phone seized after an arrest when no exigent circumstances exist. The Court held that,
officers must obtain a warrant before conducting a search of the contents of a cell phone seized
incident to an arrest. Otherwise, the action is unconstitutional; therefore, the search of the data on
a cell phone is a major invasion of privacy due to the quality and quantity of information stored
on phones.

Such scenarios are applicable in the Philippine context especially now that the
Government is in the verge of fighting the corruptive drug problem here in the country. In People
vs Del Rosario, where accused was charged and convicted by the trial court of illegal possession
of firearms and illegal possession and sale of drugs, particularly methamphetamine or shabu, it
was held that constitution specifically provides that a search warrant must particularly describe
the things to be seized. In herein case, the only objects to be seized that the warrant determined
was the methamphetamine and the paraphernalia’s therein. The seizure of the firearms was
unconstitutional. Also in People vs Aruta, the Arresting officer was tipped off by an informant
that a certain the offender will be arriving from Baguio City with a large volume of marijuana
The next day, at the they waited for the bus coming from Baguio, when the informer pointed out
who to a certain person, the team approached her and introduced themselves as NARCOM
agents. When asked about the contents of her bag, the latter handed it out to the police. They
found dried marijuana leaves. It was held that, The essential requisite of probable cause must still
be satisfied before a warrantless search and seizure can be lawfully conducted. Therefore,
accused cannot be said to be committing a crime, she was merely crossing the street and was not
acting suspiciously.

A person in authority must follow procedural rules and regulations of the law in
connection for the discharge of their official tasks. Hence, these rules, if neglected or disregarded
shall give effect in the administration of justice concerning offenses committed by certain
individuals. In the case that was mentioned there must be legal basis and probable cause to effect
a warrantless arrest of the accused’s bag, without which the accused was not lawfully arrested.
Hence, the Courts in the mentioned cases, ruled in favor of the accused because of the
irregularities manifested in the actions of the arresting officers. The Courts, heeds to the
importance of this procedural aspects because they believe that without adhering thereof, the
accused is being vulnerable with abuses therefore neglecting that essence of the rule of law
which is the administration and deliverance of justice to each and every person without
distinctions.