Facts:

The case involves the People of the Philippines as the appellee against Robert Chiu y Wan (also known as Robert Chu) and Mark Anthony Molina y Dela Peña as the accused. The events leading to the case unfolded on November 1, 1998, in Quezon City, Philippines. Robert Chiu was charged with violating Section 16 of Republic Act No. 6425, as amended by Republic Act No. 7659, for possessing 220.40 grams of methylamphetamine hydrochloride, commonly known as shabu, without the necessary license or prescription. Additionally, both Chiu and Molina were charged in a separate case for violating Section 15 of the same law, involving the sale of 1.13 grams of shabu.

The prosecution's case began with surveillance operations conducted by the Central Police District Criminal Investigation Unit, which targeted a suspected shabu dealer named Daniel Henares. Following a test-buy operation on October 5, 1998, Henares was apprehended and subsequently revealed that he had acquired the drugs fr...

Facts:

Background of the Case:
Robert Chiu y Wan and Mark Anthony Molina y Dela Peña were charged with violations of Republic Act No. 6425, as amended by Republic Act No. 7659, specifically for possession and sale of methylamphetamine hydrochloride (shabu).

Surveillance and Test-Buy Operations:
In September 1998, the Central Police District Criminal Investigation Unit conducted surveillance on suspected shabu dealer Daniel Henares. After a test-buy operation on October 5, 1998, Henares was arrested and revealed during interrogation that he obtained shabu from Robert Chiu.

Search Warrant Application:
On October 26, 1998, SPO1 Edgardo Fernandez applied for a search warrant against Chiu at the Regional Trial Court (RTC) of Pasay City, despite the location of the search being in Quezon City. Judge Lilia C. Lopez granted the warrant based on urgency and confidentiality.

Execution of Search Warrant:
On November 1, 1998, a buy-bust operation was conducted against Chiu, resulting in the purchase of shabu. Immediately after, the search warrant was executed, leading to the discovery of 220.40 grams of shabu, firearms, ammunition, and drug paraphernalia at Chiu’s rented house.

Forensic Examination:
Forensic Chemist Isidro Cariño confirmed that the seized substances tested positive for methylamphetamine hydrochloride.

Defense of the Accused:
Chiu and Molina denied the charges, alleging that they were framed and that the search warrant was invalid.

Issue:

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Ruling:

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Ratio:

1. Validity of the Search Warrant: The Court held that a search warrant could be issued by a court outside its territorial jurisdiction if justified by compelling reasons, such as urgency and confidentiality. Judge Lopez did not err in granting the search warrant despite the location being in Quezon City.

2. Proof Beyond Reasonable Doubt: The prosecution successfully established the guilt of the accused through testimonies of police officers, forensic evidence, and the execution of the search warrant.

3. Forensic Examination: A qualitative examination of a sample from the seized substances is sufficient to establish that the entire substance is shabu, as held in prior cases.

4. Constitutional Rights: The accused did not raise the issue of the validity of the search warrant or the admissibility of the seized evidence during the trial, constituting a waiver of their right to challenge these issues.

Conclusion:

The Supreme Court affirmed the conviction of Robert Chiu and Mark Anthony Molina, ruling that the search warrant was valid and the evidence against them was sufficient to prove their guilt beyond reasonable doubt.