**Facts:**
– **Initial Sighting and Arrest:**
– April 15, 2016, at approximately 10:30 p.m.
– Location: Barangay Palanan, Makati City.
– Police, led by PO3 Rojas and other SAID-SOTG operatives, executed Search Warrant SW-16-288-MN against Jay Tan for RA 9165 and illegal possession of firearms.
– The police forcibly entered the house and found Joemarie Mendoza sitting on the floor with a pen gun, a small sachet of shabu, and two improvised tooters.
– Mendoza was arrested, his rights apprised, and continued their search, finding additional illegal items in a vault.
– **Procedures and Evidence:**
– Seized items were marked, inventoried, photographed, and processed.
– Marking done by PO3 Marcelo, assisted by Barangay Kagawad Jose Villa Jr.
– Preliminary Investigation leading to the indictment:
– The City Prosecutor’s Office received various documents including the Final Investigation Report, Laboratory Exam Results, Inventory Receipt, etc.
– Recommended indictment for violations of RA 10591 and Sec. 11 & 12 of RA 9165.
– Two Informations filed at RTC Makati: Criminal Case Nos. R-MKT-16-765-CR (illegal possession of drugs) and R-MKT-16-766-CR (possession of drug paraphernalia).
– **RTC Trial:**
– Mendoza pleaded not guilty.
– Prosecution witnesses included Kagawad Villa, PO2 Gimena, and PO3 Rojas.
– The defense presented Mendoza’s denial.
– RTC convicted Mendoza for violations of Sec. 11 and 12 of RA 9165.
– **Appeal to CA:**
– CA affirmed RTC’s decision.
– Held that Mendoza could not challenge the search warrant’s legality and the evidence was validly obtained.
– It was ruled that Mendoza was found in possession of the items in plain view.
**Issues:**
1. Whether the CA erred in affirming Mendoza’s conviction despite the invalid search warrant and the inadmissibility of evidence.
2. Whether CA erred in affirming the conviction despite police non-compliance with Sec. 21, Art. II of RA 9165 as amended.
**Court’s Decision:**
– **Search Warrant’s Defects:**
– Found invalid for covering two separate offenses (RA 9165 and RA 10591), violating the one-specific-offense rule under the Revised Rules of Criminal Procedure.
– The Court invalidated the search warrant leading to the arrest and seizure.
– **Inadmissibility of Evidence:**
– Waiver of arrest validity doesn’t affect evidence inadmissibility.
– Evidence seized due to an invalid search warrant is inadmissible.
– The plain view doctrine was not applicable, as the initial intrusion was invalid.
– **Chain of Custody Rule:**
– The police failed to comply with the mandated witnesses during inventory, violating Sec. 21 of RA 9165.
– The integrity of the seized drugs was compromised, signaling a break in the chain of custody, warranting Mendoza’s acquittal.
**Doctrine:**
– **One-Specific-Offense Rule:** A search warrant must be strictly limited to one specific offense to avoid scatter-shot warrants, ensuring more precise and probable cause determinations.
– **Illegally Seized Evidence:** Evidence obtained under an invalid search warrant is inadmissible regardless of subsequent waiver to challenge the arrest.
– **Compliance with Chain of Custody:** Strict adherence to procedures in RA 9165 is necessary to maintain the integrity of evidence in drug cases.
**Class Notes:**
– **One-Specific-Offense Rule:** Procedural safeguards ensure warrants are specific and founded on probable cause.
– **Plain View Doctrine:** Requires initial lawful intrusion for the doctrine to apply and does not circumvent invalid searches.
– **Chain of Custody:** Essential to establish evidence integrity in drug cases, failure to comply necessitates acquittal.
– **Relevant Statutory Provisions:** The Revised Rules of Criminal Procedure, Sec. 21 of RA 9165, Art. III Sec. 2 of the Constitution (protection against unreasonable searches and seizures).
**Historical Background:**
– The case highlights stringent judicial interpretations aligned with protecting constitutional rights against unreasonable search and seizure.
– Reflects ongoing legal evolution to ensure police compliance with procedural and constitutional mandates in drug-related offenses.
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