Case Digest (G.R. No. 168695)
Facts:
People of the Philippines v. Maribel Lagman and Zeng Wa Shui, G.R. No. 168695*, December 08, 2008, the Supreme Court En Banc, Carpio Morales, J., writing for the Court. (Formerly G.R. Nos. 134680-82.)The appellee is the People of the Philippines; the appellants are Maribel Lagman and Zeng Wa Shui (also known as Alex Chan). The case arises from NBI surveillance and simultaneous raids on a piggery in Porac, Pampanga and a rented house in Balibago, Angeles City on March 14, 1996, pursuant to Search Warrants No. 96-102 (Porac) and No. 96-101 (Balibago). The raids followed reports of clandestine manufacture of shabu (methamphetamine hydrochloride).
From the Porac piggery (Search Warrant No. 96-102), agents found pigs and two drums later identified as acetone and ethyl; during a stakeout the NBI detained and searched vehicles that arrived: a blue Toyota Corolla driven by Li Wien Shien yielded a digital scale and a crystalline packet field-tested positive for shabu (≈317.60 g), and an L-300 Mitsubishi van driven by Zeng contained a blue drum with liquid that field-tested positive for shabu. From the Balibago residence (Search Warrant No. 96-101), agents forcibly opened two padlocked rooms and seized containers, sacks and paraphernalia; field tests on liquids from six containers were positive for shabu, sacks contained ephedrine hydrochloride, and other seized chemicals included sodium hydroxide and solvents; a .25 caliber handgun was also recovered.
Separate informations were filed: Maribel faced Criminal Case Nos. 96-377 (possession of ~527 kg methamphetamine in liquid form) and 96-378 (possession of ~1,615 kg ephedrine hydrochloride); Li was charged in Criminal Case No. 96-379 (possession of ~317.60 g methamphetamine); Zeng was charged in Criminal Case No. 96-380 (possession of approximately 78 kg methamphetamine). The cases were consolidated in Branch 59, Regional Trial Court (RTC) of Angeles City. At trial the RTC (decision dated July 20, 1988) acquitted Li but convicted Maribel and Zeng, sentencing both to death and imposing fines (P2,000,000 on Maribel and P1,000,000 on Zeng). The defendants appealed to the Court of Appeals.
The Court of Appeals affirmed the convictions by Decision dated June 6 (the CA decision appears in the record as June 6, 2006 and various references), and denied Maribel’s motion for reconsideration by Resolution dated March 30, 2007. The appellants then brought the present appeal to the Supreme Court by a petition for review (the case record states they “interposed the present appeal”), disputing primarily: (a) the validity of Search Warrant No. 96-101 and admissibility of items seized thereunder (Maribel); (b) whether Maribel had actual or constructive possession/knowledge of the contraband; (c) the admissibility of the blue drum seized from Zeng’s van and whether that drum was covered by Search Warrant No. 96-102; (d) whether the prosecution proved the lack of author...(Pro-only)
Issues:
- Was Search Warrant No. 96-101 valid and were the items seized thereunder admissible against Maribel?
- Did Maribel have actual or constructive possession and knowledge of the drugs and paraphernalia found in the rented house?
- Was the blue drum found in Zeng’s van lawfully seized and admissible (i.e., did the plain view doctrine apply and was it covered by Search Warrant No. 96-102)?
- Did the prosecution meet its burden to prove that Zeng had no authority to possess methamphetamine, and was a quantitative/purity test ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)