GR 204419; (November, 2016) (Digest)
G.R. No. 204419. November 07, 2016
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. HON. EDMAR P. CASTILLO, SR., AS PRESIDING JUDGE OF BRANCH 6, REGIONAL TRIAL COURT, APARRI, CAGAYAN AND JEOFREY JIL RABINO Y TALOZA, RESPONDENTS.
FACTS
The Municipal Trial Court (MTC) of Gattaran, Cagayan, issued Search Warrant No. 45 based on an application by law enforcement officers. The warrant authorized a search of private respondent Jeofrey Jil Rabino’s residence in Aparri, Cagayan, for violations of R.A. No. 9165. The search yielded a sachet containing methamphetamine hydrochloride residue, leading to the filing of an Information for illegal possession of dangerous drugs against Rabino before the Regional Trial Court (RTC) of Aparri.
Before arraignment, Rabino filed a Motion to Quash the Search Warrant. The RTC, presided by respondent Judge Castillo, granted the motion. It ruled that the MTC of Gattaran lacked jurisdiction to issue the warrant because the penalty for the offense—possession of shabu—exceeds six years imprisonment, which is beyond the MTC’s jurisdiction. The court declared the warrant null and void, suppressed the evidence obtained, and dismissed the criminal case.
ISSUE
Whether the Regional Trial Court committed grave abuse of discretion in quashing Search Warrant No. 45 on the sole ground that the issuing Municipal Trial Court lacked jurisdiction over the offense subject of the warrant.
RULING
Yes, the RTC committed grave abuse of discretion. The Supreme Court clarified that the authority to issue a search warrant is not co-extensive with the jurisdiction to try the criminal case. The power to issue search warrants is conferred by the Constitution and the Rules of Court to any court, regardless of whether it has jurisdiction over the offense, provided it has territorial jurisdiction over the place to be searched. The requisites for a valid warrant are: (1) probable cause determined personally by the judge; (2) the judge must examine the complainant and witnesses under oath; and (3) the warrant must particularly describe the place and things to be seized.
In this case, the MTC of Gattaran had territorial jurisdiction as both Gattaran and Aparri are within the province of Cagayan. The RTC erred in invalidating the warrant based solely on the MTC’s lack of jurisdiction over the drug offense, which is a matter for trial. The issuing court’s competence is determined by its territorial jurisdiction relative to the location of the search, not by the nature or penalty of the crime being investigated. Consequently, the quashal of the warrant and the dismissal of the case were reversed, and the criminal case was ordered reinstated.