G.R. No. 135503 ; July 6, 2000
WILLIAM A. GARAYGAY, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

The Executive Judge of the Regional Trial Court (RTC) of Manila, Branch 23, issued Search Warrant No. 96-505 against petitioner William Garaygay, authorizing a search of his residence in Lapu-Lapu City, which is outside Manila’s jurisdiction. The search yielded firearms and explosives, leading to the filing of an Information for violation of P.D. No. 1866 before the RTC of Lapu-Lapu City. Petitioner filed a Motion to Quash the Search Warrant and to Exclude Illegally Seized Evidence with the Lapu-Lapu City RTC, arguing the warrant was a general warrant and issued in violation of Supreme Court Circular No. 19. The prosecution countered that the motion should be filed with the Manila RTC, the issuing court.

ISSUE

Which court has jurisdiction to resolve a motion to quash a search warrant when the criminal case is filed in a court different from the one that issued the warrant?

RULING

The Supreme Court ruled that the RTC of Lapu-Lapu City, where the criminal case is pending, has jurisdiction to resolve the motion to quash. The Court clarified the procedural guidelines from Malaloan v. Court of Appeals. While the general rule is that a motion to quash should be filed with the issuing court, an exception exists when the criminal case is filed in another court. To promote orderly administration of justice and avoid confusion, all incidents relating to the validity of the warrant, including a motion to quash, should be consolidated with the court trying the criminal case. This ensures a single forum for resolving both the criminal liability and the admissibility of evidence obtained under the warrant. The Court set aside the Court of Appeals’ decision and directed the Lapu-Lapu City RTC to resolve the motion to quash with dispatch.