G.R. No. 166061 - Quel y Quino vs. People

The petition for review seeks to reverse the Decision of the Court of Appeals affirming the Regional Trial Court's (RTC) ruling that found Andy Quelnan y Quino guilty of violating the Dangerous Drugs Act of 1972.
The Information against the petitioner alleged possession of 27.7458 grams of Methamphetamine Hydrochloride (Shabu) without legal authorization.
During arraignment, the petitioner pleaded not guilty, leading to a trial where prosecution witnesses testified about the events surrounding the search and seizure.

On August 27, 1996, a police team executed a search warrant at the Cityland Condominium in Makati City.
The police, accompanied by a security officer, approached Unit 615, where the petitioner was present.
Upon entering the unit, the police discovered three sachets of shabu and various drug paraphernalia.
The petitioner was arrested, and evidence was submitted to the National Bureau of Investigation (NBI) for examination, confirming the presence of shabu.

The petitioner claimed he was merely collecting rent from his tenant, Sung Kok Lee, and was not in possession of the drugs.
He testified that he was forced to sign documents at gunpoint during the search.
Witnesses for the defense included the condominium administrator and the petitioner’s driver, who corroborated his claims of being the owner of the unit and his presence there for legitimate reasons.

The RTC found the petitioner guilty based on the credible testimonies of the police officers who conducted the search.
The court noted the presumption of regularity in the performance of official duties and found no evidence of ill-will or bad faith among the officers.
The RTC sentenced the petitioner to imprisonment, relying on the evidence presented during the trial.

The Court of Appeals affirmed the RTC's ruling but modified the penalty imposed on the petitioner.
The appellate court addressed the validity of the search warrant and the circumstances surrounding the petitioner’s arrest.

The primary issues were whether the search warrant was properly enforced and whether the petitioner was validly arrested without a warrant.
The prosecution argued that the petitioner was caught in flagrante delicto, justifying the warrantless arrest.

The search warrant was issued for a specific location and did not need to name the occupant for validity.
The petitioner’s argument that the warrant was invalid due to the omission of his name was rejected, as the warrant clearly described the premises to be searched.
The court emphasized that the police were authorized to search the premises and seize any illegal items found therein.

The petitioner contended that he was not in possession of the drugs, but the court clarified that possession could be actual or constructive.
The prosecution established that the petitioner had control over the premises where the drugs were found, thus supporting the claim of possession.
The court noted that the petitioner’s presence in the unit at the time of the search and the nature of the items found were sufficient to establish his culpability.

The court concluded that the petitioner’s control and dominion over the drugs were sufficiently established by the circ...continue reading