MANILA — The Supreme Court (SC) has ruled that items seized during a lawful warrantless arrest may be admitted as evidence even if they are not in plain view of arresting officers.

In a 16-page decision, the SC’s First Division upheld the conviction of a drug suspect, clarifying that the plain view doctrine merely supplements, but does not always limit, the justification for a valid warrantless search.

“For these reasons, compliance with the plain view doctrine is not always required to justify a warrantless search and seizure. This is especially true if the search is limited to the person of the accused, where the seized items are usually hidden,” the decision stated.

Authored by Associate Justice Ricardo Rosario, the ruling, issued in October 2025 and made public in February 2026, emphasized that officers conducting a lawful body search may seize hidden items intended as evidence.

The case involved a San Carlos City resident arrested in a 2017 buy-bust operation. During a search, officers found three sachets of suspected shabu hidden inside a cellphone charger. The accused argued that the items should be inadmissible as they were not in plain view.

The Regional Trial Court and the Court of Appeals had already convicted him of illegal possession of shabu. The SC affirmed the rulings, noting that the plain view requirement does not always apply in lawful warrantless searches.

The accused was sentenced to a maximum of 16 years in prison.