Case Digest (G.R. No. 8765)
Facts:
In People of the Philippines vs. Huang Zhen Hua and Jogy Lee, the Public Assistance and Reaction Against Crime (PARAC) unit under the Department of Interior and Local Government received information from a confidential informant that Peter Chan, Henry Lao, and appellants Jogy Lee and Huang Zhen Hua were engaged in illegal drug trafficking, with Lee handling the accounting of proceeds (surveillance conducted at various restaurants in Manila and in condominium units in Makati and Parañaque). On October 25, 1996, Judge William M. Bayhon of the Regional Trial Court (RTC) of Manila issued Search Warrant No. 96-801 for illegal firearms and explosives and Search Warrant No. 96-802 for violations of Sections 12, 14, and 16, Article III, Republic Act No. 6425, as amended. On October 29, the police executed Warrant No. 96-801 at Cityland Condominium, finding two kilos of methamphetamine hydrochloride (shabu) and paraphernalia. Earlier, on October 26, a shoot-out at Furama Laser Karaoke ReCase Digest (G.R. No. 8765)
Facts:
- Surveillance and Intelligence
- PARAC operatives received a tip that Peter Chan, Henry Lao, appellants Lee and Huang were trafficking shabu; surveillance confirmed Lee and Lao cohabited and met Chan at restaurants and a hotel.
- The suspects’ residences were identified at Cityland Condominium (Rooms 1245, 1247) and Pacific Grand Villa, Parañaque.
- Search Warrants and Seizures
- On October 29, 1996, Warrant No. 96-801 was served at Cityland: officers found 2 kg of shabu, production paraphernalia, and counterfeit‐card equipment.
- On October 26, 1996, a raid at Furama Karaoke resulted in the death of Chan and Lao and seizure of 2 kg shabu from Lao’s car. The same day, Warrant No. 96-802 was executed at Pacific Grand Villa: after knock, interpreter assistance, and Lee’s voluntary opening of the door, officers found in the master bedroom two 1-kg bags of shabu, a bottle and canister with shabu, paraphernalia, and personal documents.
- Post-Seizure Procedures and Prosecution
- Inventory and arrest affidavits were made; exhibits were delivered to the PNP Crime Laboratory, whose report confirmed methamphetamine hydrochloride.
- An Information was filed charging Lee and Huang with violation of Sec. 16, RA 6425; they were arraigned on November 29, 1996, and pleaded not guilty.
Issues:
- Issues Concerning Huang Zhen Hua
- Did the prosecution prove beyond reasonable doubt his actual or constructive possession of shabu or conspiracy with Lao and Chan?
- Issues Concerning Jogy Lee
- Were the search and seizure lawful under the “knock and announce” rule, warrant requirements, and due-process (including interpreter assistance)?
- Was the evidence of contraband planted, and did Lee’s lack of English comprehension vitiate her knowledge of the shabu?
- Was there probable cause for her warrantless arrest and for seizing items not described in the warrant?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)