Case Summary (G.R. No. L-2873)
Factual Background
Two Informations were filed against Enriquez for (1) illegal possession of drug paraphernalia and (2) illegal possession of dangerous drugs under Republic Act No. 9165. The case arose out of a search conducted on May 3, 2017, delineated with specific evidence of illegal substances found on the premises during the search executed under the aforementioned warrant. Enriquez pleaded not guilty upon arraignment.
Procedural History
The Regional Trial Court ultimately found Enriquez guilty. His conviction was affirmed, with modifications, by the Court of Appeals, which increased the penalty he faced for illegal possession of dangerous drugs from 12 to 14 years of imprisonment and imposed a fine.
Applicable Law
The rights concerning searches and seizures are grounded in Article III, Section 2 of the 1987 Philippine Constitution, which protects individuals from unreasonable intrusions and mandates that search warrants must particularly describe the place to be searched and the items to be seized.
Validity of the Search Warrant
The Court of Appeals upheld the validity of the search warrant, asserting it sufficiently described the location and objects to be seized, although it acknowledged some imperfections in the address. However, the Supreme Court disagreed with this assessment, finding that the warrant's description was overly broad and did not meet the constitutional requirement of particularly describing the premises.
Execution of the Search Warrant
The Supreme Court also scrutinized the execution of the search warrant, concluding that PDEA agents violated the "knock and announce" rule mandated by the Revised Rules of Criminal Procedure, by failing to announce their authority prior to entering the premises. It noted that Enriquez's surprise during the agents' entry indicated the lack of communication regarding their identity and purpose.
Chain of Custody
The Court examined the chain of custody of the seized items, asserting that it was imperatively maintained by prosecution witnesses. However, the determination of whether procedural requirements were adequately followed in this regard proved inconsequential given the invalid execution of the search warrant itself.
Rights Violation and Evidence Admissibility
The ruling emphasized the fundamental right against unreasonable search and seizure. The failure in execution of the warrant and the lack of proper proced
...continue readingCase Syllabus (G.R. No. L-2873)
Background and Charges
- Accused-appellant Lucky Enriquez y Casipi was charged with two counts: illegal possession of dangerous drugs and illegal possession of drug paraphernalia under Republic Act No. 9165.
- Two Informations: Criminal Case No. R-QZN-17-05641-CR (drug paraphernalia) and Criminal Case No. R-QZN-17-05642-CR (dangerous drugs).
- Items seized included improvised tooters, lighters, aluminum foils, scissors, plastic sachets, and white crystalline substance containing methamphetamine.
- Enriquez pleaded not guilty, and trial ensued.
Facts Surrounding the Search and Seizure
- Philippine Drug Enforcement Agency (PDEA) obtained Search Warrant No. 5368 (2017) issued by Quezon City Regional Trial Court.
- Warrant executed on May 3, 2017, at Informal Settler's Compound, Barangay Pinyahan, Quezon City.
- Search team composed of 30 PDEA agents led by Agent Cham D. Sulit.
- Agents entered the house through an open door without prior announcement.
- Enriquez attempted to flee but was caught and arrested.
- Search was witnessed by media representative and Barangay Kagawad.
- Seized items were inventoried and turned over to PDEA laboratory.
Trial Court's Findings and Ruling
- The Regional Trial Court found Enriquez guilty beyond reasonable doubt of both charges.
- The search warrant description deemed sufficient as agents could identify the house.
- Open door entry and arrest before presentation of warrant justified due to possibility of escape and Enriquez's awareness of agents' authority.
- Chain of custody of evidence found unbroken despite minor inconsistencies in witness testimonies.
- Sentenced Enriquez to prison terms and fines; seized items forfeited to government.
Court of Appeals Decision
- Affirmed the conviction with modification on penalty for illegal possession of dangerous drugs (life imprisonment and higher fine).
- Held the search warrant valid despite imprecise address and absence of sketch map in record.
- Justified the search execution as complying substantially with &quo