GR L 37393 94; (October, 1974) (Digest)
G.R. Nos. L-37393-94 October 23, 1974
HON. PEDRO TEMPLO, Judge, City Court; ROBERTO M. RODRIGUEZ, JR., 1st Assistant City Fiscal, Naga City; and ELIAS PAMA, Chief of Police, Naga City, petitioners, vs. HON. JUDGE RAFAEL DELA CRUZ, Court of First Instance of Camarines Sur and MANUEL YEE CONCEPCION, respondents.
FACTS
On June 16, 1972, search warrants issued by petitioner Judge Pedro Templo of the Naga City Court led to the seizure of untaxed “blue seal” cigarettes and foreign wines from a hotel room. An information for violation of the National Internal Revenue Code was subsequently filed on September 4, 1972, with the same City Court against respondent Manuel Yee Concepcion, and a warrant for his arrest was issued. The offense charged was within the concurrent jurisdiction of the City Court and the Court of First Instance (CFI).
Respondent Concepcion, instead of seeking relief in the City Court which issued the warrants and took cognizance of the criminal case, filed two separate petitions for injunction with the CFI of Camarines Sur, presided by respondent Judge Rafael dela Cruz. These petitions sought to restrain the fiscal from using the seized articles as evidence and to stop the chief of police from enforcing the arrest warrant. The CFI consolidated the cases and, in a decision dated November 27, 1972, granted the injunctive relief, ordering the return of the records to the City Court and inhibiting the use of the seized evidence.
ISSUE
Whether the Court of First Instance acted without jurisdiction in taking cognizance of and granting injunctive relief in the petitions filed by respondent Concepcion, considering that the criminal case was already pending before the City Court, a court of concurrent jurisdiction.
RULING
Yes. The Supreme Court granted the petition for certiorari, reversed the CFI decision, and set it aside. The ruling is anchored on the fundamental principle of judicial hierarchy and the prohibition against interference by a co-equal court. Once a court of concurrent jurisdiction, like the City Court in this case, has taken cognizance of a criminal case, another court of concurrent jurisdiction, such as the CFI, is devoid of authority to interfere with its proceedings through ancillary writs like injunction. The proper remedy for questioning the validity of the search warrants or challenging the proceedings was to seek relief directly from the City Court that issued them and before which the criminal case was pending, not from a coordinate court.
The Supreme Court, citing precedents such as Pagkalinawan v. Gomez, emphasized that a court may not control or restrain the acts of another court of equal rank. The CFI’s assumption of jurisdiction to issue injunctive relief against the processes of the City Court was a clear overreach. With this dispositive jurisdictional issue, the Court found it unnecessary to delve into the other grounds raised by the petitioners. The decision underscores that the validity of the search warrants and the legality of the arrest must be ventilated in the very court that issued the processes and is hearing the main criminal action.