The Supreme Court has reiterated the necessity for search warrants to clearly specify the location to be searched, emphasizing that failure to meet this standard renders them invalid and violates the constitutional right against unlawful searches and seizures.

In a landmark decision penned by Senior Associate Justice Marvic M.V.F. Leonen, the Second Division of the Supreme Court acquitted Lucky Enriquez of charges involving illegal possession of dangerous drugs and drug paraphernalia under Republic Act No. 9165, or the Comprehensive Dangerous Drugs Act of 2002. The Court's ruling centered on a defective search warrant and irregularities in its execution.

The case originated from a 2017 operation by the Philippine Drug Enforcement Agency (PDEA). Acting on a search warrant, PDEA agents were tasked to locate and seize dangerous drugs and paraphernalia at “Informal Settler’s Compound, NIA Road, Barangay Pinyahan, Quezon City.” However, the warrant lacked precision in identifying the exact location within the compound, prompting legal challenges.

During the operation, PDEA agents, guided by an informant, entered a residence where Enriquez was located. They failed to knock or announce their presence and forcibly entered the premises, seizing sachets allegedly containing shabu. The Regional Trial Court convicted Enriquez, and the Court of Appeals later upheld the conviction.

The Supreme Court overturned these rulings, declaring the search warrant invalid for being overly broad and effectively a general warrant, which is expressly prohibited by the Constitution. The lack of specific details in the warrant granted the enforcement officers unrestrained discretion to search the entire compound, a clear violation of constitutional safeguards.

Additionally, the Court found procedural flaws in the warrant's execution. Under Rule 126, Sections 7 and 8 of the Rules of Court, law enforcement agents are required to identify themselves and seek permission before entering the premises. Forced entry is permitted only when entry is denied. This protocol protects the occupants and minimizes risks of violence during such operations.

In Enriquez's case, the agents failed to comply with these procedures. They entered the house without prior notice or consent and conducted the search without the lawful occupant witnessing the process. The Supreme Court emphasized that searches must be carried out in the presence of the lawful occupant or, if unavailable, at least two credible witnesses from the area.

This decision underscores the judiciary's role in upholding constitutional rights and ensuring law enforcement adheres to due process. The acquittal of Enriquez sets a critical precedent for cases involving defective search warrants and procedural lapses.