GR 173861; (July, 2014) (Digest)
G.R. No. 173861 , July 14, 2014
JAY CANDELARIA and ERIC BASIT, Petitioners, vs. REGIONAL TRIAL COURT, BRANCH 42, CITY OF SAN FERNANDO; (Pampanga) represented by its Presiding Judge HON. MARIA AMIFAITH S. FIDER-REYES, OFFICE OF THE PROVINCIAL PROSECUTOR, CITY OF SAN FERNANDO, PAMPANGA and ALLIED DOMECQ PHILIPPINES, INC., Respondents.
FACTS
Petitioners Jay Candelaria and Eric Basit were arrested during a buy-bust operation on June 22, 2001, for allegedly delivering five cases of counterfeit Fundador Brandy with intent to sell. They were charged with violation of the Intellectual Property Code. After arraignment and pleading not guilty, they filed a Motion to Suppress/Exclude Evidence, contending the evidence (the counterfeit products) was obtained in violation of their constitutional right against unreasonable searches and seizures, as they were not committing a crime in the presence of the arresting officers to justify a warrantless search and seizure. The Regional Trial Court (RTC) denied the motion in an Order dated October 12, 2005, finding that the search and seizure was incidental to a valid warrantless arrest as the accused were caught in flagrante delicto, and noting that any objection to an arrest must be made before arraignment. Their Motion for Reconsideration was denied in an Order dated July 14, 2006.
ISSUE
Whether the Regional Trial Court, Branch 42 of the City of San Fernando, Pampanga committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the petitioners’ motion to set the case for a suppression hearing.
RULING
The Supreme Court DISMISSED the Petition for Certiorari. The Court held that:
1. The petition was dismissible for failure to allege that there is no appeal nor any plain, speedy, and adequate remedy in the ordinary course of law, which is an indispensable requirement for a petition for certiorari under Rule 65.
2. Assuming the RTC’s Order was erroneous, the mistake would be an error of judgment, not jurisdiction, and is correctible by appeal, not certiorari. The RTC’s determination on the admissibility of evidence was an exercise of its jurisdiction.
3. Petitioners failed to show that the RTC acted with grave abuse of discretion. The RTC thoroughly considered the pleadings and the Joint Affidavit of the arresting officers before rendering its judgment.
4. Petitioners violated the principle of hierarchy of courts by filing the petition directly with the Supreme Court instead of with the Court of Appeals, as petitions for certiorari assailing interlocutory orders of the RTC should be filed with the Court of Appeals absent special and important reasons, which were not present in this case.