GR 132839; (November, 2001) (Digest)
G.R. No. 132839 November 21, 2001
ERIC C. ONG, petitioner, vs. HON. COURT OF APPEALS and THE PEOPLE OF THE PHILIPPINES, respondents.
FACTS
On July 4, 1995, the Regional Trial Court (RTC) of Batac, Ilocos Norte, Branch 17, issued Search Warrant No. 17 against petitioner Eric C. Ong, leading to the seizure of firearms and ammunition. A criminal case was subsequently filed against Ong in RTC Laoag City, Branch 15. Ong then filed a Motion to Recall the search warrant before the issuing court (RTC Branch 17), which granted the motion and ordered the release of the seized items. The prosecution moved for reconsideration, arguing that RTC Branch 17 had lost jurisdiction to recall the warrant once the criminal case was filed in another branch.
The prosecution’s motion was denied. The Office of the Solicitor General then filed a petition for certiorari with the Court of Appeals (CA). The CA granted the petition, setting aside the RTC Branch 17’s orders. It ruled that the court hearing the criminal case (RTC Branch 15) had jurisdiction to resolve any challenge to the search warrant’s validity, citing People vs. Bans. The CA denied Ong’s motion for reconsideration.
ISSUE
Which court has jurisdiction to resolve a motion questioning the validity of a search warrant—the court that issued it or the court hearing the criminal case arising from its execution?
RULING
The Supreme Court denied the petition and affirmed the CA. The Court held that jurisdiction over a motion to quash or recall a search warrant lies with the court conducting the trial of the criminal case, not with the issuing court, once the criminal case is filed. This rule, established in Nolasco v. Paño and reiterated in the en banc decision of People vs. Bans, aims to prevent confusion and promote the orderly administration of justice. It avoids the absurd situation where the trial judge would be bound by another court’s ruling on the warrant’s validity, thereby impairing the trial court’s independent assessment of evidence.
The Court clarified that petitioner’s reliance on People vs. Woolcock was misplaced, as Woolcock did not modify or reverse the en banc ruling in Bans. Under constitutional rules, a division of the Court cannot reverse a doctrine established by the Court en banc. Furthermore, procedural adherence in this context does not violate constitutional rights against illegal searches. Petitioner retains the remedy of filing a motion to suppress evidence before the trial court. The policy of consolidating incidents relating to the search warrant with the criminal case ensures judicial order and efficiency.