PEOPLE OF THE PHILIPPINES, appellee, vs. AMADEO TIRA and CONNIE TIRA, appellants.
FACTS
Appellants Amadeo Tira and Connie Tira were charged with violating the Dangerous Drugs Act. Based on a police surveillance report of alleged drug activities at their residence, a search warrant was issued. On March 9, 1998, a police team implemented the warrant at the Tira house. They found Amadeo inside. The search of his room yielded several sachets of suspected shabu, drug paraphernalia, and cash. The seized items were confirmed to be methamphetamine hydrochloride and marijuana by forensic examination. The spouses were convicted by the Regional Trial Court and sentenced to reclusion perpetua and a fine.
At trial, the defense claimed the search was illegal, alleging the police entered without the warrant, planted the evidence, and that Amadeo was forced to sign an inventory. They argued the warrant was invalid for failing to particularly describe the place to be searched, as it mentioned “the first room on the right side” and “two rooms located at Perez south,” which they claimed was ambiguous.
ISSUE
The core issue is whether the search warrant was validly issued and implemented, and whether the evidence obtained therefrom is admissible to sustain the conviction.
RULING
The Supreme Court affirmed the conviction. The search warrant was valid. The requirement of particularity in describing the place to be searched is satisfied if the description enables the officer to locate the premises with reasonable certainty. The warrant described the Tira residence at Perez Extension Street, and the accompanying sketch provided further clarity. The police team, which conducted prior surveillance, had no difficulty locating and searching the specific house and room. The alleged ambiguity was inconsequential.
The defense of frame-up was rejected for lack of clear and convincing evidence. The police officers were presumed to have regularly performed their duties, and their testimonies on the search and seizure were consistent and credible. The detailed inventory, presence of a barangay official during the search, and the forensic reports corroborated the lawful recovery of the illegal drugs. The finding of shabu and marijuana in the room under Amadeo’s control established constructive possession, which, coupled with the drug paraphernalia and cash, supported the finding of guilt beyond reasonable doubt for illegal possession of dangerous drugs. The penalties imposed by the trial court were upheld.
