Facts:

• The petitioner, Andy Quelnan y Quino, was charged with violating Section 16, Article III of Republic Act No. 6425 (The Dangerous Drugs Act of 1972).
• The incident occurred on August 27, 1996, in Makati City.
• A team from the Police Assistance and Reaction Against Crime (PARAC) of the Department of the Interior and Local Government (DILG) executed a search warrant issued by the Regional Trial Court (RTC) of Manila on August 26, 1996.
• The team, composed of several police officers, went to Unit 615 of the Cityland Condominium in Makati City.
• They sought assistance from the building's security office and were accompanied by Security Officer Celedonio Punsaran to Unit 615.
• Upon knocking, a male person, later identified as the petitioner, opened the door.
• The police presented the search warrant and conducted a search, finding three transparent plastic sachets containing methamphetamine hydrochloride (shabu), plastic tubings, weighing scales, an improvised burner, and empty plastic sachets.
• The petitioner was arrested and brought to the PARAC office for investigation.
• The National Bureau of Investigation (NBI) forensic chemist confirmed the seized items to be shabu.
• The petitioner was charged and found guilty by the RTC, which sentenced him to imprisonment.
• The Court of Appeals affirmed the RTC's decision but modified the penalty.
• The petitioner sought the reversal of the judgment, questioning the validity of the warrantless arrest and the enforcement of the search warrant.

Issue:

• (Unlock)

Ruling:

1. The search warrant was properly enforced.
2. The petitioner was validly ...(Unlock)

Ratio:

• The Supreme Court upheld the validity of the search warrant's enforcement and the warrantless arrest of the petitioner.
• The search warrant was issued for the search of specifically described premises, not for a person.
• The omission of the petitioner's name in the search warrant did not invalidate it, as the legal description of the premises was correct.
• The search warrant directed the police to search the premises and seize the shabu, and to bring any persons found in possession of the drugs to be dealt with as the law directs.
• The petitioner was found in flagrante delicto, meaning he was caught in the act of possessing the illegal drugs, justifying his warrantless arrest.
• Possession includes both actual and constructive possession:
  • Actual possession: The drug is in the immediate physical possession or control of the accused.
  • Constructive possession: The drug is under the dominion and control of the accused or within a place where the accused has control.
• The petitioner had constructive possession of the shabu, as it was found on top of a table in a small room where he was the only person present.
• The petitioner's familiarity with the premises, his ha...continue reading