GR 118151; (August, 1996) (Digest)
G.R. No. 118151 August 22, 1996
WASHINGTON DISTILLERS, INC., MANUEL CO KEHYENG, CHONGKING KEHYENG, QUIRINO KEHYENG, JASMIN KEHYENG and PURITA KEHYENG, petitioners, vs. COURT OF APPEALS and LA TONDEΓA DISTILLERS, INC., respondents.
FACTS
Private respondent La TondeΓ±a Distillers, Inc., manufacturer of Ginebra San Miguel gin, filed a complaint alleging petitioners Washington Distillers, Inc. and the Kehyengs were unlawfully using its registered 350cc round white flint bottles with blown-in marks. Based on affidavits from NBI agents and La TondeΓ±a’s counsel detailing surveillance where they posed as bottle dealers and saw thousands of such bottles in petitioners’ Pampanga warehouse, Executive Judge Rosalio G. de la Rosa of the RTC Manila, Branch XXVIII, issued Search Warrant No. 93-64. The NBI seized 314,289 bottles from petitioners’ premises in San Fernando, Pampanga. Petitioners moved to quash the warrant, arguing the RTC Manila lacked territorial jurisdiction to issue a warrant for execution in Pampanga, and that no probable cause existed under Republic Act No. 623 . Assisting Judge Antonio L. Descallar granted the motion, also finding private respondent guilty of forum-shopping due to prior applications for warrants in Pampanga. The Court of Appeals reversed this order on certiorari.
ISSUE
Whether the Regional Trial Court of Manila had jurisdiction to issue a search warrant for execution in San Fernando, Pampanga.
RULING
Yes. The Supreme Court affirmed the Court of Appeals and held that any court, including the RTC of Manila, possesses the authority to issue search warrants enforceable nationwide. This ruling is grounded in the constitutional requirement that search warrants be issued only by a judge, without any territorial restriction on the warrant’s reach. The Court clarified that a search warrant is a judicial process, not an action in court, and its validity is not constrained by the territorial jurisdiction of the issuing court over the place of execution. The power to issue such warrants is inherent in all courts and is necessary for the effective administration of justice, particularly in combating crimes that transcend local boundaries. The Court emphasized that the key safeguards are the determination of probable cause by the judge and the specific procedures under Rule 126 of the Rules of Court, which must be meticulously observed regardless of where the warrant is issued. Consequently, the RTC Manila committed no jurisdictional error. The Court also found the finding of forum-shopping by the assisting judge to be erroneous, as the previous applications in Pampanga involved different factual circumstances and judicial determinations.
