GR 164321; (November, 2006) (Digest)
G.R. No. 164321; November 30, 2006
SKECHERS, U.S.A., INC., Petitioner, vs. INTER PACIFIC INDUSTRIAL TRADING CORP., et al., Respondents. TRENDWORKS INTERNATIONAL CORPORATION, Petitioner-Intervenor.
FACTS
Petitioner Skechers, a foreign corporation not doing business in the Philippines but holding registered trademarks for “SKECHERS” and an “S” oval design for footwear, engaged a private investigator. The investigation revealed respondents were importing and selling shoes bearing an “S” logo. Based on an affidavit and testimony from the investigator, the Regional Trial Court (RTC) issued Search Warrant Nos. 02-2827 and 02-2828 for violation of the Intellectual Property Code (Infringement under Sec. 155). The warrants were executed, leading to the seizure of thousands of pairs of shoes from a warehouse and retail outlet.
Respondents moved to quash the warrants. The RTC granted the motion, quashing Search Warrant No. 02-2827 (covering the warehouse) and ordering the return of seized items. The court found no probable cause, ruling that the applicant’s witness had no personal knowledge of the alleged illegal importation and that the application failed to specifically describe the items to be seized. The Court of Appeals affirmed the RTC’s decision. Skechers elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s order quashing the search warrant for lack of probable cause.
RULING
The Supreme Court granted the petition, reversed the assailed decisions, and reinstated Search Warrant No. 02-2827. The legal logic centered on the established standards for determining probable cause in search warrant applications. Probable cause requires facts and circumstances sufficient to engender a well-founded belief that a crime has been committed and the items sought are connected to it and located at the place to be searched.
The Court held that the RTC and the Court of Appeals erred in their assessment. The applicant’s witness, the private investigator, had personal knowledge derived from his own surveillance and purchases at the respondent’s premises. His affidavit and testimony detailing the presence of shoes with the allegedly infringing “S” logo at the specific warehouse were sufficient to establish probable cause. The Court further ruled that the description of the items in the warrant—”shoes bearing the ‘S’ logo”—was specific enough, as it would be impossible to list each pair individually. The warrant particularly described the property to be seized as those falling under the offense of trademark infringement. The quashal was therefore improper, as the issuing judge had conducted a searching examination and correctly found probable cause based on the witness’s personal knowledge.