### **Facts:**
This case originated in the Regional Trial Court (RTC) of Manila, which convicted Tiu Won Chua and Qui Yaling for violating Section 16, Article III of the Dangerous Drugs Act of 1972, as amended, for illegal possession of methamphetamine hydrochloride (“shabu”). The prosecution’s case stemmed from a surveillance operation that led to a successful test-buy, warrant application, and subsequent search of a unit in HCL Building, revealing substantial quantities of shabu. The appellants, Tiu Won Chua and Qui Yaling, contested the validity of the search warrant and the evidence obtained. Despite their defenses, the RTC found them guilty, sentencing them to reclusion perpetua and a fine of P500,000.00 each, propelling them to appeal to the Supreme Court.
### **Issues:**
1. Was the search warrant valid despite an error in naming one of the persons to be searched and not including the other?
2. Did the search of the vehicle, not specified in the warrant, violate the constitutional rights of the accused?
3. Were the elements of illegal possession of dangerous drugs satisfactorily proven beyond reasonable doubt?
### **Court’s Decision:**
On the first issue, the Supreme Court upheld the validity of the search warrant, emphasizing the correct description of the place over the precise identification of the accused. The Court clarified that the authorities’ prior knowledge and the operation details compensated for the name discrepancy.
For the second issue, the Court determined the search of the vehicle parked a distance from the described premises to be unlawful, as it was not included in the search warrant nor incidental to a lawful arrest.
Regarding the third issue, the Court found sufficient evidence proving the appellants’ possession of the illegal drugs within the searched premises, affirming Tiu Won Chua’s conviction based on his possession of a larger quantity in his man’s handbag and modifying Qui Yaling’s sentence due to the smaller quantity found in her handbag, with both acknowledging ownership.
### **Doctrine:**
The case reiterates the doctrine that a search warrant’s validity hinges on its description of the place to be searched more than the precise identification of the individual(s). It also underscores the principle that errors in naming in a warrant do not invalidate the warrant provided the location is correctly described. Lastly, it highlights the principle that possession of a dangerous drug, as a malum prohibitum offense, does not require proof of intent for conviction.
### **Class Notes:**
– Legal Elements of Illegal Drug Possession: (1) Possession of the prohibited substance, (2) Lack of legal authority, (3) Conscious possession.
– Doctrine of “Fruits of the Poisonous Tree”: Evidence obtained through illegal searches cannot be used in court, with the vehicle search being a direct application.
– Importance of Precise Location in Search Warrants: A valid search is limited to the specific location described in the warrant.
– Ownership Admissions in Court: Admissions regarding possession or ownership of items (e.g., handbags) can significantly impact the outcome.
– *Malum Prohibitum* Offenses: Lack of intent does not absolve individuals from liability in crimes inherently wrong by legislative determination.
### **Historical Background:**
This case is embedded in the context of the Philippines’ long-standing battle against illegal drugs, reflecting rigorous enforcement of the Dangerous Drugs Act of 1972 and its subsequent amendments. It underscores judicial scrutiny over law enforcement actions and the balance between combating crime and upholding constitutional rights.
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