327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can a search warrant executed without specific reference
to a store within the premises lead to a conviction for possession of illegal
drugs under the Comprehensive Dangerous Drugs Act of 2002 (RA 9165), even if
the accused argues that the store was separate from their residence?
People of the Philippines vs. Sundaram Magayon y
Francisco
Date of Promulgation: September 16, 2020
FACTS OF THE CASE:
Sundaram Magayon y Francisco was convicted by the trial
court for violation of Section 11, Article II of RA 9165, or the Comprehensive
Dangerous Drugs Act of 2002. On August 3, 2004, the police, armed with a search
warrant, conducted a buy-bust operation at Magayon's residence and store in
Butuan City. During the operation, law enforcement witnessed a transaction
between Magayon and a police informant, resulting in the seizure of marijuana
packets.
After the buy-bust, the police executed a search warrant at
the premises. They confiscated a total of 381.3065 grams of marijuana,
including multiple small packets and dried stalks. Magayon’s defense centered
around procedural flaws, claiming the search was invalid because the warrant
did not explicitly include the store where the marijuana was found, asserting
that the store and residence were separate.
At trial, the court found Magayon guilty of illegal
possession of drugs. The trial court ruled that the store was part of the
residence, and therefore, the search warrant was valid. It also held that the
prosecution sufficiently proved Magayon’s control over the premises where the
drugs were found, despite his protests that his girlfriend rented the store.
The court imposed a sentence of 20 years and one day to 30 years in prison,
along with a fine of P500,000.
Magayon appealed to the Court of Appeals, which upheld the
conviction, affirming that the search was valid and the evidence properly
admitted. Magayon further appealed to the Supreme Court.
PRIMARY ISSUE IN THE SUPREME COURT:
Did the Court of Appeals err in affirming the validity of
the search warrant and the subsequent conviction of Magayon for illegal
possession of drugs, considering his argument that the store was not properly
covered by the warrant?
SUPREME COURT RULING:
The Supreme Court denied the appeal and affirmed the
decision of the Court of Appeals. The Court ruled that the search warrant
sufficiently described the place to be searched, which included Magayon’s
"rented residence and its premises," thus covering both the house and
the store. The Court emphasized that the constitutional requirement for
particularity in search warrants is satisfied if the premises to be searched
can be identified with reasonable certainty. In this case, the store was part
of the residence and not a separate entity.
Furthermore, the Supreme Court rejected Magayon's challenge
to the chain of custody of the seized drugs, noting that his own
counter-affidavits admitted his possession of the marijuana, and the
testimonies of the police officers sufficiently established the integrity and
identity of the seized items. The Court upheld the lower court’s findings of
guilt beyond reasonable doubt for illegal possession of marijuana.
DISPOSITIVE PORTION:
“ACCORDINGLY, the appeal is DENIED, and the Decision dated
January 26, 2018, in CA-G.R. CR-HC No. 01411-MIN is AFFIRMED. Sundaram Magayon
y Francisco is found GUILTY of illegal possession of drugs under Section 11,
Article II of RA 9165, and sentenced to an indeterminate penalty of twenty (20)
years and one (1) day as minimum to thirty (30) years as maximum and to pay a
fine of five hundred thousand pesos (P500,000.00) without subsidiary
imprisonment in case of insolvency.”
Should the scope of search warrants be broadened to
include nearby establishments within the same premises, even if not
specifically mentioned in the warrant?
IMPORTANT DOCTRINES:
- Sufficient
Particularity in Search Warrants:
A description of the place to be searched is sufficient if the officer with the warrant can, with reasonable effort, identify the place and distinguish it from other places in the community. This includes areas that form part of the same premises, even if not explicitly described, as long as the accused has control over the entire area. - Constructive
Possession:
Possession under RA 9165 includes both actual possession, where the drug is in the immediate physical possession of the accused, and constructive possession, where the drug is under the dominion and control of the accused or located in premises controlled by the accused. - Chain
of Custody Rule:
The prosecution must prove an unbroken chain of custody from the time of confiscation until the drugs are presented in court. However, admissions made by the accused regarding possession of drugs can validate the integrity of seized evidence, even if there are minor lapses in procedural compliance.
Classification of the Case:
Criminal Law – Violation of the Comprehensive Dangerous
Drugs Act of 2002 (RA 9165)
From <https://chatgpt.com/c/66eebb42-ae6c-800a-8fcb-4ef8af71d5bf>
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📚 Welcome, future
lawyers and legal enthusiasts! This short quizzer focuses on a criminal law
case that reached the Supreme Court of the Philippines and presents key legal
issues on drug-related offenses, constitutional rights, and evidentiary rules.
Today’s quiz is based on the case People of the
Philippines vs. Sundaram Magayon y Francisco, G.R. No. 238873,
promulgated on September 16, 2020. It involves a charge of illegal
possession of dangerous drugs, where the accused was arrested following a
buy-bust and search operation at a residence and store allegedly under his
control.
The main issue revolved around the validity of the search
warrant, the accused’s control over the premises, and whether the
evidence seized could be used to convict him. The Supreme Court affirmed the
conviction, ruling that the store was part of the rented premises and that constructive
possession was established through the accused’s own judicial admissions
and the surrounding circumstances.
Make sure to watch until the end—the answer key will be
provided at the end of this video. Let's test your knowledge and critical
thinking skills!
📝 10 EASY DIFFICULTY HOTS
(Higher Order Thinking Skills) MULTIPLE CHOICE QUESTIONS:
1.
Which legal concept was key in affirming the accused’s
liability despite him not being the owner of the property where the drugs were
found?
A. Actual possession
B. Legal presumption
C. Constructive possession
D. Prescriptive control
2.
Why did the Supreme Court rule that the search of the store
was valid under the search warrant?
A. Because the store had no separate entrance
B. Because it was mentioned explicitly in the warrant
C. Because the accused waived his right to object
D. Because it was part of the described rented premises
3.
What did the Supreme Court say about the accused’s failure
to object to the validity of the search warrant during trial?
A. It strengthened the defense
B. It was considered a waiver of the objection
C. It rendered the search unconstitutional
D. It led to a mistrial
4.
Which of the following statements best reflects the Court’s
view on the credibility of the accused’s counter-affidavits?
A. They were inadmissible because not made in open court
B. They were void because they lacked legal assistance
C. They were binding since they were made with counsel and
voluntarily
D. They were ignored due to inconsistency
5.
What defense was raised by the accused regarding ownership
of the seized drugs?
A. He was never at the location
B. He was merely a bystander
C. He claimed he was only a user, not a seller
D. He denied the existence of any drugs
6.
How did the Court address the accused’s claim that the
search warrant failed to specify the store?
A. It declared the search warrant null
B. It ruled that specificity is irrelevant
C. It held the description was sufficient as the store was
part of the rented residence
D. It emphasized that only explicit descriptions are valid
7.
What role did the accused’s live-in partner play in the
case?
A. She owned the drugs and confessed
B. She was declared a co-conspirator
C. She was present but not charged, and he claimed the drugs
belonged to her ex-husband
D. She assisted the police in the operation
8.
Which circumstance supported the Supreme Court’s finding of
the accused’s guilt beyond reasonable doubt?
A. The confession of a barangay official
B. His admission in notarized affidavits about the drugs
C. The testimony of his former lawyer
D. The lack of a defense counsel during trial
9.
What was the penalty imposed on the accused by the courts?
A. Life imprisonment and a P1,000,000 fine
B. 12 years imprisonment and community service
C. 20 to 30 years imprisonment and a P500,000 fine
D. Acquittal due to insufficient evidence
10.
Which principle did the Court affirm regarding search
warrants and the areas to be searched?
A. They must be strictly limited to one room
B. They must list every item and room specifically
C. They are sufficient if they allow officers to identify
the place with reasonable effort
D. They apply only to the person, not the premises
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