G.R. No. 94396 November 27, 1992
PEOPLE OF THE PHILIPPINES, petitioner, vs. HON. COURT OF APPEALS, HON. ABELARDO DAYRIT, presiding Judge of Manila, Regional Trial Court, Br. 39 and RUBEN SIAO, respondents.

FACTS

The National Bureau of Investigation (NBI) secured a search warrant from Judge Abelardo Dayrit to seize 27 distribution transformers from respondent Ruben Siao’s warehouse. The transformers, originally sold and delivered to the University of the Philippines-Iloilo (UP) by Danilo Varona of Varona Trading, were later fraudulently pulled out by Varona under the pretext of repairs. The NBI found them in Siao’s possession, with crates still marked “UP-Iloilo.” Siao moved to quash the warrant, claiming his company, Nissen-Denki Philippine Corporation, purchased the transformers from Varona. After extensive pleadings, Judge Dayrit initially denied the motion but later granted reconsideration and dissolved the warrant, ordering the transformers’ return to Siao.
Meanwhile, UP filed an estafa case against Varona and Siao. Upon reinvestigation, the prosecution moved for the dismissal of the case against Siao, which the Iloilo RTC granted. The petitioner, through the Solicitor General, appealed to the Court of Appeals to reinstate the search warrant, arguing it complied with constitutional requirements. The CA sustained the trial court’s quashal, noting the issue became moot as the transformers had been dismantled and converted.

ISSUE

Whether the Court of Appeals erred in refusing to reinstate the search warrant.

RULING

The Supreme Court denied the petition, upholding the Court of Appeals. The search warrant was null and void for failing to state the specific offense for which it was issued, a constitutional imperative under Article III, Section 2. The warrant’s caption left the offense blank, and its body vaguely described the transformers as “stolen or embezzled,” which could refer to robbery, theft, or estafa. This fatal defect rendered the warrant invalid ab initio.
Moreover, the Court found the issue moot and academic. The transformers, the specific objects of the warrant, no longer existed in their original form, having been dismantled and converted beyond the warrant’s description. Probable cause against Siao had also dissipated since the estafa case against him was dismissed on the prosecution’s own motion. While evidence obtained through an invalid warrant is inadmissible, the Court clarified that UP’s remedy lies in a separate civil action for restitution against Varona. The trial court’s dissolution of the warrant and the CA’s affirmation were therefore correct.