G.R. No. 264473 , August 07, 2024
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. LUCKY ENRIQUEZ Y CASIPI, ACCUSED-APPELLANT.

FACTS

Two Informations were filed against accused-appellant Lucky Enriquez y Casipi for illegal possession of drug paraphernalia (Criminal Case No. R-QZN-17-05641-CR) and illegal possession of dangerous drugs (Criminal Case No. R-QZN-17-05642-CR) under Sections 12 and 11, respectively, of Republic Act No. 9165 , allegedly committed on May 3, 2017, in Quezon City. He pleaded not guilty.
The prosecution’s evidence showed that on May 3, 2017, a Philippine Drug Enforcement Agency (PDEA) team implemented Search Warrant No. 5368 (2017), issued against alias Espando, alias Freddie, and Enriquez for an “Informal Settler’s Compound, NIA Road, Barangay Pinyahan, Quezon City,” to search for shabu and drug paraphernalia. The team, led by Agent Cham D. Sulit, proceeded to the target area. Upon arrival, agents entered the house through an open door. Enriquez, who was on the first floor, ran upstairs but was apprehended by Agent Freddie L. Bannagao. He was brought downstairs, arrested, handcuffed, and presented with the search warrant. Agent Jake Edwin L. Million then searched the first floor and found a blue “Kipling” pouch in a cabinet drawer. The pouch contained 26 plastic sachets of white crystalline substance and various drug paraphernalia. The items were marked and inventoried in the presence of media representative Jimmy Mendoza and Barangay Kagawad Edwin Bernal. The seized items were later examined by the PDEA Laboratory Service, which found the sachets and a plastic tooter positive for methamphetamine hydrochloride. Enriquez’s drug test was negative.
The defense presented a different version. Enriquez testified he was sleeping when armed men in PDEA uniforms entered his house and searched his cabinets without presenting any warrant. He was only handcuffed and arrested after identifying himself.
The Regional Trial Court found Enriquez guilty beyond reasonable doubt for both charges. The Court of Appeals affirmed the conviction with modification. Hence, this appeal.

ISSUE

The core issue is whether the search warrant was validly implemented, and consequently, whether the evidence seized is admissible against the accused.

RULING

The Supreme Court GRANTED the appeal. It REVERSED and SET ASIDE the Decision of the Court of Appeals and ACQUITTED accused-appellant Lucky Enriquez y Casipi.
The Court ruled that the search conducted was unlawful and the seized items inadmissible. The search warrant described the place to be searched as “Informal Settler’s Compound, NIA Road, Barangay Pinyahan, Quezon City.” This description is a generic designation of a wide area and does not specify with particularity the dwelling or house of the accused, as required by the Constitution and the Rules of Court. The implementing officers did not ascertain the specific sub-location or house number within the compound. The failure to specify the particular place to be searched with reasonable particularity rendered the warrant a general warrant, which is constitutionally infirm. Consequently, the warrant could not justify the search of Enriquez’s specific house. The search being unlawful, all items seized are considered fruits of the poisonous tree and inadmissible in evidence. Without the illegally seized drugs and paraphernalia, there is no evidence to sustain Enriquez’s conviction.