Facts:

The case involves Andy Quelnan y Quino (petitioner) as the accused against the People of the Philippines (respondent). The events transpired on August 27, 1996, in Unit 615 of the Cityland Condominium located in Makati City, Philippines. The petitioner was charged with violating Section 16, Article III of Republic Act No. 6425, also known as The Dangerous Drugs Act of 1972, for possessing 27.7458 grams of Methamphetamine Hydrochloride (shabu) without legal authorization. The Regional Trial Court (RTC) of Makati City, Branch 138, found him guilty and sentenced him to imprisonment.

On the day of the incident, a police team from the Police Assistance and Reaction Against Crime (PARAC) executed a search warrant issued by the RTC of Manila. Upon arrival at the condominium, the police were assisted by the building's security officer and proceeded to Unit 615, where they encountered the petitioner, who opened the door half-naked. The police presented the search warrant and co...

Facts:

Background and Accusation

• Petitioner Andy Quelnan y Quino was charged with violating Section 16, Article III of Republic Act (R.A.) No. 6425, as amended (The Dangerous Drugs Act of 1972), for possessing 27.7458 grams of methamphetamine hydrochloride (shabu) without legal authority on August 27, 1996, in Makati City.

Execution of the Search Warrant

• A police team from the Police Assistance and Reaction Against Crime (PARAC) executed a search warrant issued by the Regional Trial Court (RTC) of Manila on August 26, 1996, for Room 615 of Cityland Condominium in Makati.
• The warrant named "Bernard Lim" (later corrected to "Bernard Kim") as the subject, but it did not name the occupant of the premises.
• Upon arrival, the police, accompanied by a security officer, knocked on the door of Unit 615, which was opened by petitioner, who was half-naked.
• The police presented the search warrant and proceeded to search the unit, finding shabu, drug paraphernalia, and other items on top of a bedroom table.
• Petitioner was arrested and brought to the PARAC office for investigation.

Petitioner’s Defense

• Petitioner claimed he was the owner of Unit 615 but had leased it to Sung Kok Lee (Lee) since May 1996.
• He testified that he went to the unit on August 27, 1996, to collect rent from Lee. Upon arrival, he was greeted by a maid who left to buy refreshments. Shortly after, the police barged in, searched the unit, and forced him to sign documents at gunpoint.
• Petitioner denied knowledge of the shabu and claimed he was not in possession of the drugs.

Trial Court and Appellate Court Decisions

• The RTC found petitioner guilty of illegal possession of shabu, sentencing him to two (2) years, four (4) months, and one (1) day of prision correccional as minimum to four (4) years, nine (9) months, and ten (10) days of prision correccional as maximum.
• The Court of Appeals affirmed the conviction but modified the penalty to six (6) months of arresto mayor as minimum to three (3) years and six (6) months of prision correccional as maximum.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Search Warrant Validity: A search warrant need not name the occupant of the premises to be searched, as long as the place is specifically described. The warrant in this case met the requisites under Section 4, Rule 126 of the Revised Rules of Criminal Procedure.
2. Warrantless Arrest: A warrantless arrest is valid if the accused is caught in flagrante delicto. Petitioner’s possession of shabu was established by his control and dominion over the premises where the drugs were found. His presence, half-naked state, and representation as the owner of the unit supported the conclusion that he had knowledge of and control over the drugs.
3. Penalty Modification: The quantity of shabu (27.7458 grams) warranted a penalty under prision correccional. Applying the Indeterminate Sentence Law, the Court imposed a modified penalty to reflect the appropriate range.

Conclusion:

The Supreme Court upheld petitioner’s conviction for illegal possession of shabu, ruling that the search warrant was validly enforced and that petitioner was lawfully arrested without a warrant. The penalty was modified to reflect the correct range under the law.