Facts:

The case involves the appeal of Jogy Lee and Huang Zhen Hua against their conviction for violating Section 16, Article III of Republic Act No. 6425, as amended, by the Regional Trial Court (RTC) of Parañaque City, Metro Manila. The events leading to the case began when police operatives from the Public Assistance and Reaction Against Crime (PARAC) received information from a confidential informant regarding illegal drug trafficking activities involving Peter Chan, Henry Lao, and the appellants. Surveillance operations confirmed that Lee was managing the financial aspects of the drug trafficking activities. On October 25, 1996, the police secured two search warrants for illegal possession of firearms and drugs.

On October 29, 1996, police executed the first search warrant at the Cityland Condominium, where they discovered two kilos of methamphetamine hydrochloride (shabu) and paraphernalia for its production. Following this, they received information about a drug delivery a...

Facts:

Background Information

The case involves appellants Huang Zhen Hua and Jogy Lee, who were convicted by the Regional Trial Court (RTC) of Parañaque City for violating Section 16, Article III of Republic Act No. 6425, as amended, which pertains to the illegal possession of regulated drugs. The prosecution alleged that the appellants were part of an illegal drug trafficking ring operated by Peter Chan and Henry Lao.

Surveillance and Search Warrants

Police operatives from the Public Assistance and Reaction Against Crime (PARAC) received intelligence from a confidential informant that Chan, Lao, and the appellants were engaged in illegal drug activities. Surveillance operations confirmed that Lao and appellant Lee were living together in a condominium unit in Parañaque. Two search warrants were secured for violations of firearms and illegal drugs.

Execution of Search Warrants

On October 29, 1996, police executed Search Warrant No. 96-801 at the Cityland Condominium in Makati, where they found two kilos of methamphetamine hydrochloride (shabu), drug paraphernalia, and tools for making fake credit cards. Another search was conducted at the Pacific Grand Villa in Parañaque under Search Warrant No. 96-802, where police found shabu, drug paraphernalia, and assorted documents in the master bedroom, which appellant Lee shared with Lao.

Apprehension of Appellants

Appellant Lee was found in the condominium unit and was arrested after the search. Appellant Huang Zhen Hua, who was sleeping in another room, was also arrested. Both were brought to the PARAC headquarters, and the seized items were sent to the PNP Crime Laboratory for testing, which confirmed the presence of shabu.

Issue:

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Ruling:

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Ratio:

1. On Possession: To establish possession under Section 16 of RA 6425, the prosecution must prove the accused had knowledge and control over the illegal drugs. Constructive possession suffices if the accused had dominion over the place where the drugs were found.
2. On Search and Seizure: The police complied with the "knock and announce" rule before executing the search warrant. Any articles not listed in the warrant but found in plain view during a lawful search may still be seized if connected to the crime.
3. On Conspiracy: Conspiracy must be proved beyond reasonable doubt and cannot be presumed from mere association or presence at the scene.