Title
People vs. Huang Zhen Hua
Case
G.R. No. 139301
Decision Date
Sep 29, 2004
Appellants Huang Zhen Hua and Jogy Lee were convicted for illegal drug possession. Huang was acquitted due to lack of evidence linking him to the drugs, while Lee's conviction was upheld as she shared joint possession with her partner. The search was deemed lawful, and evidence admissible.

Case Summary (G.R. No. 78592)

Parties

Appellee/Petitioner before the Supreme Court: People of the Philippines. Appellants/Respondents before the Supreme Court: Huang Zhen Hua and Jogy Lee (convicted by the RTC and appealed).

Key Dates

Search warrants secured October 25, 1996 (Search Warrants No. 96-801 and No. 96-802). Main search and arrests and related events occurred October 26–29, 1996 (including a fatal shootout at about 2:00 a.m. on October 26). Laboratory examination and reports dated October 26, 1996. Trial court judgment convicting both appellants rendered January 10, 1999. The Supreme Court decision on appeal was rendered September 29, 2004.

Applicable Law and Constitutional Basis

Primary statutory provisions: Section 16, Article III of Republic Act No. 6425, as amended (the Dangerous Drugs Law) and related provisions amended by R.A. 7659; also searches under Presidential Decree No. 1866 (illegal possession of firearms and explosives) were the subject of one warrant. Constitutional protection invoked and applied: the guarantee against unreasonable searches and seizures under the 1987 Philippine Constitution. Procedural rule cited: Section 7, Rule 126 of the Revised Rules of Criminal Procedure (knock-and-announce requirement).

Procedural History

An Information charging violation of Section 16, R.A. No. 6425 was filed in the Regional Trial Court (Parañaque City, Branch 259). Both appellants pleaded not guilty; the trial court convicted both on January 10, 1999 and imposed reclusion perpetua and fines. Both appealed to the Supreme Court. The Office of the Solicitor General conceded reasonable doubt as to Huang Zhen Hua but sought affirmance as to Jogy Lee. The Supreme Court, applying the 1987 Constitution, reversed and acquitted Huang Zhen Hua and affirmed the conviction of Jogy Lee.

Material Facts Established at Trial

Police surveillance (based on a confidential informant) placed Lao, Chan and the appellants together on multiple occasions and established Lao and Chan’s residences at two condominium units. Police obtained search warrants for the Cityland Condominium and for Unit No. 19 Atlantic Drive (Pacific Grand Villa). A search of the Cityland unit (about October 29, 1996) yielded two kilos of methamphetamine hydrochloride ("shabu") and paraphernalia. A prior encounter at or near a karaoke restaurant (October 26, 1996) resulted in a shootout in which Chan and Lao were shot dead and two one-kilo plastic bags of shabu were recovered in Lao’s car. At Pacific Grand Villa, police approached Unit No. 19, knocked and used a Cantonese interpreter to communicate; appellant Lee peeped through a window, the police identified themselves by uniform and through the interpreter, and Lee opened the door and allowed police, the security officer and security guards into the unit. During the search of the master’s bedroom the police found two heat-sealed plastic bags (approximately 1,000.40 g and 998.10 g), a baby feeding bottle and a small plastic canister containing additional crystalline substance, paraphernalia, and documents and personal items in a headboard drawer. Anciro, Jr. placed initials on the seized items and, together with Ferias, delivered them to the PNP Crime Laboratory, which reported the substances as positive for methamphetamine hydrochloride.

Prosecution Evidence and Certifications

The prosecution introduced: the search warrants; testimony of PARAC officers describing surveillance, entry and the discovery of the drugs and paraphernalia; certifications by the security officer and guards that the search was orderly and nothing was destroyed; an affidavit of arrest and inventory; chain-of-custody actions (initialing of seized packages) and laboratory Chemistry Report No. D-1243-96 confirming methamphetamine hydrochloride in the seized specimens; and documentary evidence found in the bedroom (bank passbooks, passports, credit cards, photographs) linking the unit occupants to the premises and to one another.

Defense Assertions and Testimony

Jogy Lee testified she was a Belgian passport holder from China visiting the Philippines as a tourist, lived with Lao at the condominium unit, could not understand or speak English, and claimed the police did not properly show her the search warrant, that the police planted the shabu in her bedroom while she visited the co-appellant’s room, and that police demanded ransom. She asserted she had no knowledge of illegal drug activities. Huang Zhen Hua testified he arrived in the Philippines on October 22, 1996 as a tourist at Lee’s invitation, was a temporary guest with no control over the unit, his room was searched but no drugs were found there, and he disavowed any participation in drug trafficking or conspiracy.

Issues Raised on Appeal

Major issues included whether the prosecution proved possession beyond reasonable doubt (actual or constructive) and conspiracy; whether the search and entry into Unit No. 19 violated the Constitution and Rule 126 (knock-and-announce); whether items seized not particularly described in the warrant were admissible; whether there was planting of evidence; whether probable cause existed for arrest; and whether the appellants were deprived of due process (including the provision of an interpreter).

Legal Standards Applied by the Court

The Court applied the standard elements of unlawful possession under Section 16, R.A. No. 6425: (1) accused is found in possession of a regulated drug; (2) lack of lawful authorization; and (3) knowledge of the nature of the drug. Possession may be actual or constructive; constructive possession requires dominion and control or a right to exercise dominion and control over the place where the contraband is found, and it may be joint rather than exclusive. Conspiracy cannot be presumed and must be proved beyond reasonable doubt. For searches of dwellings, the constitutional protection against unreasonable searches and seizures and the knock-and-announce principle (Section 7, Rule 126) were applied; the Court recognized exceptions to a no-knock requirement, the plain view doctrine, and the presumption of regularity in police conduct absent clear and convincing proof of misconduct.

Court’s Analysis and Ruling as to Huang Zhen Hua

The Court concluded the evidence against Huang Zhen Hua was insufficient to prove either actual or constructive possession or any participation in a conspiracy. There was no showing that drugs were found on his person or in his room; his presence at several social occasions did not establish dominion or control over the premises or the contraband; surveillance testimony was equivocal as to identifying him; and no overt acts indicative of common design were proved. Given the presumption of innocence and the prosecution’s failure to prove knowledge, dominion or conspiracy beyond reasonable doubt, the Supreme Court granted the appeal as to Huang Zhen Hua, reversed the RTC conviction, acquitted him, and directed his release unless detained for another cause.

Court’s Analysis and Ruling as to Jogy Lee

The Court affirmed the conviction of Jogy Lee. It found the police complied with the knock-and-announce requirement: they coordinated with the condominium security, knocked for several minutes, announced their presence and purpose through the security officer and a Cantonese interpreter, and Lee opened the door and allowed entry. The Court rejected Lee’s claim of forcible entry and planting of evidence as not established by clear and convincing proof; the security officer’s certification that nothing was destroyed and his testimony supported the regularity of the entry and search. The Court applied the plain view doctrine to admit unlisted items seen during a lawful search and found the documents and personal effects bore an intimate nexus to the crime. Lee’s act of taking clothes from the very cabinet where the shabu were found supported joint constructive possession with Lao. The Court also held that there was probable cause for Lee’s warrantless arrest given the information from the informant corroborated by surveillance and the circumstances observed upon entry. The presence of a Cantonese interpreter at the time of the search and during trial was noted; the Court found no denial of due process in that regard.

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