G.R. No. 173861 - Candelaria vs. Regional Trial Court, Branch 42, City of San Ferdo

Petitioners Jay Candelaria and Eric Basit were arrested on the evening of June 22, 2001, during an alleged buy-bust operation conducted at the corner of Gueco St. and MacArthur Highway, Balibago, Angeles City.
They were apprehended for allegedly delivering, with intent to sell, five cases of counterfeit Fundador Brandy.
Based on the Joint Affidavit of the arresting officers, the petitioners were charged on July 6, 2004, in an Information for violation of Section 155 in relation to Section 170 of Republic Act No. 8293 (the Intellectual Property Code of the Philippines).

Following arraignment on May 31, 2005, where petitioners pleaded not guilty, they filed a Motion to Suppress/Exclude Evidence on June 17, 2005.

The motion alleged that the evidence (i.e., the seized counterfeit products) was obtained in violation of their constitutional right against unreasonable searches and seizures.
Petitioners argued that at the time of seizure, the products were not in plain view, nor were they committing or attempting a crime in the presence of the arresting officers.

The Regional Trial Court (RTC), Branch 42, City of San Fernando, Pampanga, rendered an Order dated October 12, 2005, denying the Motion to Suppress/Exclude Evidence.

The RTC based its decision on the premise that any objection to an arrest should be raised prior to arraignment.
It further relied on established jurisprudence which holds that failing to move for a quash of the information before arraignment estops the accused from later questioning the legality of the arrest.
The RTC held that the search and seizure was incidental to a valid warrantless arrest, catching the accused in flagrante delicto, hence deeming the evidence admissible.

Unsatisfied with the denial of the suppression motion, petitioners filed a Motion for Reconsideration.
The RTC issued another Order on July 14, 2006, denying the Motion for Reconsideration.

The denial reiterated that the timing of the motion (after arraignment) precluded a substantive challenge to the legality of the arrest or the admissibility of the evidence.

Petitioners subsequently filed a Petition for Certiorari with an Application for Preliminary Injunction, challenging the RTC’s Orders.
The sole ground of the petition was that the RTC, Branch 42, committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying their motion for a suppression hearing.
The petition was further criticized for failing to show that no plain, speedy, and adequate remedy in the ordinary course of law existed, a requirement for appeals under Rule 65 of the Rules of Court.
Additionally, the petitioners raised the issue on the proper timing for filing a motion to suppress/exclude evidence, admitting that it was a pure question of law.

Whether the Regional Trial Court (RTC), Branch 42, committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the petitioners' Motion to Suppress/Exclude Evidence.

Whether the error in the RTC’s decision was one of jurisdiction or merely an error in judgment.
Whether petitioners properly exhausted other plain, speedy, and adequate remedies before resorting to a petition for certiorari.
The appropriate timing for filing a motion to suppress/exclude evidence, considering that objections to arrest-related matters should have been raised prior to arraignment.