Warrantless search, seizure of vessels, aircrafts for violations of customs laws

Search and seizure without search warrant of vessels and aircrafts for violations of customs laws have been the traditional exception to the constitutional requirement of a search warrant. It is rooted on the recognition that a vessel and an aircraft, like motor vehicles, can be quickly moved out of the locality or jurisdiction in which the search warrant must be sought and secured. Yielding to this reality, judicial authorities have not required a search warrant of vessels and aircrafts before their search and seizure can be constitutionally effected. The same exception ought to apply to seizures of fishing vessels and boats breaching our fishery laws. These vessels are normally powered by high-speed motors that enable them to elude arresting ships of the Philippine Navy, the Coast Guard and other government authorities enforcing our fishery laws. We thus hold as valid the warrantless search on the F/B Robinson, a fishing boat suspected of having engaged in illegal fishing. The fish and other evidence seized in the course of the search were properly admitted by the trial court. [G.R. No. 119619. December 13, 1996]