Facts:

The case involves petitioners Rafael Zafe III, also known as "Pait," and Cherryl Zafe y Camacho, who were charged with violations of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) and Republic Act No. 10591 (Comprehensive Firearms and Ammunition Regulation Act). The events leading to the case began on June 24, 2015, when Presiding Judge Lelu P. Contreras of the Regional Trial Court Branch 42 in Virac, Catanduanes, issued Search Warrant No. 2015-45. The warrant was based on the application of PO1 Domingo Bilaos, an intelligence operative from the San Andres Municipal Police Station, and a confidential informant, who testified under oath that Rafael Zafe was in possession of illegal drugs, specifically "shabu," at his residence in Barangay Sta. Cruz, San Andres, Catanduanes. The police executed the search warrant on the same day, recovering illegal drugs, drug paraphernalia, and live ammunition for an M-16 rifle. Following their arrest, Ra...

Facts:

Background

Petitioners Rafael Zafe III and Cherryl Zafe challenged the validity of Search Warrant No. 2015-45, issued by Presiding Judge Lelu P. Contreras of the Regional Trial Court (RTC) of Virac, Catanduanes. The warrant authorized the search of their residence for illegal drugs and paraphernalia under Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). During the search, police officers allegedly recovered drugs, drug paraphernalia, and live ammunition.

Criminal Charges

Petitioners were charged with:

1. Criminal Case No. 5524: Possession of drug paraphernalia under Section 12, Article II of RA 9165.
2. Criminal Case No. 5525: Unlawful possession of ammunition under Section 28(g) of RA 10591 (Comprehensive Firearms and Ammunition Regulation Act).

Motion for Production of Records

Petitioners filed a Motion for Production of Records, requesting the court to provide copies of the depositions and records of the examinations conducted during the search warrant application. They argued that these records were necessary to verify if the judge personally examined the witnesses and if the warrant was validly issued. The trial court denied the motion, citing the need to protect the identities of confidential informants.

Appeal to the Court of Appeals

Petitioners elevated the case to the Court of Appeals (CA) via a Petition for Certiorari, Mandamus, and Prohibition. The CA affirmed the trial court’s denial, stating that the identities of the confidential informants must be protected.

Supreme Court Petition

Petitioners filed a Petition for Review on Certiorari with the Supreme Court, arguing that the denial of their Motion for Production violated their constitutional rights to due process, public information, and evidence in their defense.

Issue:

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Ruling:

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Ratio:

1. Right Against Unreasonable Searches and Seizures: The Court emphasized that the determination of probable cause for a search warrant must be based on a personal and thorough examination of the applicant and witnesses by the issuing judge. The absence of records showing such examination rendered the search warrant invalid.

2. Presumption of Regularity Rebutted: The issuing judge’s claim of regularity in performing her duties was insufficient to overcome the petitioners’ rights, especially when there was no evidence on record to support her finding of probable cause.

3. Right to Due Process and Evidence: Petitioners were entitled to examine the search warrant’s supporting documents to prepare their defense. The denial of this right violated their constitutional right to due process.

4. State’s Interest vs. Constitutional Rights: While the State has an interest in protecting confidential informants, this interest cannot outweigh the accused’s constitutional rights. The Court ruled that the prosecution failed to justify the denial of access to the records as the least restrictive means of protecting the informants.

5. Invalidity of Search Warrant: The warrant was deemed a general warrant due to its lack of specificity in describing the place to be searched and the items to be seized. This defect, combined with the absence of supporting records, rendered the warrant void and the evidence obtained inadmissible.

6. Dismissal of Criminal Charges: The Court dismissed the criminal charges against petitioners, citing the violation of their right to a speedy trial and the inadmissibility of the evidence obtained through the invalid search warrant.

Conclusion:

The Supreme Court held that the trial court and the Court of Appeals committed grave abuse of discretion in denying petitioners access to the search warrant records. The search warrant was declared void, the evidence obtained was inadmissible, and the criminal charges were dismissed.