Case Digest (G.R. No. 246017)
Facts:
In Antonio U. Sio v. People of the Philippines (G.R. No. 224935, March 2, 2022), petitioner Antonio U. Sio was charged with illegal possession of shabu and drug paraphernalia under Republic Act No. 9165 after a search warrant was issued by the Regional Trial Court, Lucena City, Branch 59, on October 22, 2010. The application, filed by Police Senior Inspector Paulino G. Raguindin, alleged that Sio stored methamphetamine hydrochloride and used two vehicles—a Toyota Camry (plate ZYR-468) and a Honda Civic (plate ZGS-763)—for trafficking at his residence in Ilaya Ibaba, Purok 34, Barangay Dalahican, Lucena City. When operatives executed the warrant on October 24, 2010, they entered Barangay Purok 3A, recovered an undetermined amount of crystalline substance later confirmed as shabu, a .45 caliber pistol with live ammunition, two magazines, and two cars bearing different plate numbers. Sio’s omnibus motion to quash the search warrant and determine probable cause was denied by the triCase Digest (G.R. No. 246017)
Facts:
- Search warrant application and issuance
- On October 22, 2010, P/S Insp. Paulino G. Raguindin filed an application for a search warrant before the Manila RTC, Branch 59, alleging that petitioner Antonio U. Sio was storing an undetermined quantity of shabu, drug paraphernalia, and “other vital documents” at his residence in Ilaya Ibaba, Purok 34, Barangay Dalahican, Lucena City, and was using two vehicles—a Toyota Camry (Plate No. ZYR-468) and a Honda Civic (Plate No. ZGS-763)—for drug trafficking.
- The trial court granted the warrant after hearing testimony from P/S Insp. Raguindin and PO3 Pepito C. San Pedro.
- Implementation and seizure
- On October 24, 2010, PNP-AIDSOTF operatives executed the warrant at Barangay Purok 3A, instead of Ilaya Ibaba, Purok 34, and seized:
- An undetermined quantity of suspected shabu, later positive in laboratory tests.
- A .45 caliber Remington pistol with ammunition and magazines.
- Two vehicles: a Honda CRV (Plate No. XPX-792) and a Toyota Camry (Plate No. ZRY-758).
- No Philippine Drug Enforcement Agency agents, media representatives, or barangay officials were present during the initial entry; they arrived approximately three hours later.
- Criminal charges and lower-court proceedings
- Two Informations were filed charging Sio with (a) illegal possession of shabu (¢116.16 g) and (b) possession of drug paraphernalia, under RA 9165, Sections 11 and 12.
- Sio moved for judicial determination of probable cause, challenged warrant irregularities (wrong address, nonexistent/incorrect vehicles, absence of required witnesses, alleged planting of evidence). The RTC denied the Omnibus Motion and issued an arrest warrant on May 7, 2013; its denial of reconsideration followed on April 15, 2014.
- Sio’s Rule 65 petition for certiorari before the CA was dismissed on November 27, 2015; reconsideration denied on May 10, 2016.
- On July 1, 2016, Sio filed a Petition for Review under Rule 45 before the Supreme Court.
Issues:
- Whether the implementation of the search warrant was unreasonable, rendering the seized evidence inadmissible.
- Whether there was probable cause for filing the two Informations for violation of RA 9165.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)