G.R. No. 165483 - Palaganas vs. People

Accused-appellant Lucky Enriquez y Casipi was charged with illegal possession of dangerous drugs and illegal possession of drug paraphernalia under Sections 11 and 12 of Republic Act No. 9165.
The charges stem from a series of search warrants issued by the Regional Trial Court of Quezon City for a property described as "Informal Settler's Compound, NIA Road, Barangay Pinyahan, Quezon City."
Specifically, Search Warrant No. 5368 (2017) targeted the subject house as a drug den operated by alias Espando, alias Freddie, and Enriquez.

On May 3, 2017, a team of 30 Philippine Drug Enforcement Agency (PDEA) agents led by Agent Cham D. Sulit executed the search warrant.
Agents entered the house through an open door around 6:00 p.m. without formally announcing their authority or showing the warrant prior to entry.
Enriquez was found on the first floor, attempted to flee upstairs but was arrested and handcuffed by Agent Freddie L. Bannagao.
The search led to the seizure of 26 sachets containing white crystalline substance, drug paraphernalia including improvised tooters, disposable lighters, aluminum foils, scissors, and empty sachets.
The seized items were inventoried and photographed, and the drugs tested positive for methamphetamine hydrochloride (shabu).

Enriquez testified he was asleep and was abruptly awakened by loud noises and found PDEA agents searching his house without prior announcement.
He asserted that the agents did not show the search warrant until after his arrest.

The Regional Trial Court found Enriquez guilty beyond reasonable doubt on both counts, upholding the validity of the search warrant and its proper execution despite minor irregularities.
The Court of Appeals affirmed Enriquez's conviction, modifying his penalty to life imprisonment and fine.
The lower courts held that the agents located the house with the help of a confidential informant and that the warrant's description, although somewhat general, was sufficient.
They also accepted that Enriquez's attempt to escape justified the unannounced entry.

Validity of the search warrant based on its description of the premises.
Proper execution of the search warrant, particularly compliance with the "knock and announce" rule.
Admissibility of the seized evidence given alleged violations.

Whether Search Warrant No. 5368 (2017) was valid, specifically if it sufficiently described the place to be searched.

Whether the Philippine Drug Enforcement Agency properly executed the search warrant in compliance with constitutional and procedural rules, especially the "knock and announce" principle under Rule 126, Sections 7 and 8 of the Rules of Court.

Whether the evidence seized during the search was admissible given the circumstances of the search and seizure.