G.R. No. L-3195 - People vs Quiroga

On April 12, 1986, Judge Lauro V. Francisco of the Regional Trial Court (RTC) of Cebu City Branch XIII issued a search warrant after examining 2Lt. Dennis P. Canoy and two other witnesses.
The warrant directed the search of the premises of R.R. Construction at M.J. Cuenco Avenue, Cebu City, and the seizure of an Isuzu dump truck with plate number GAP-175.
At noon of the same day, respondent Canoy seized the vehicle and took custody.

On April 14, 1986, petitioner Romeo S. Chua filed a civil action for Replevin and Sum of Money in RTC Cebu City Branch VIII (Civil Case No. CEB-4384), asserting lawful ownership and possession of the dumped truck.
Petitioner denied having sold, stolen, or carnapped the vehicle and questioned the validity of the search warrant and subsequent seizure.
On the same date, Judge Leonardo B. Canares of Branch VIII ordered the issuance of a writ of replevin upon the posting of a bond of P100,000.00. Deputy Sheriff Galicano V. Fuentes seized the vehicle on April 15, 1986.

On April 16, 1986, respondent Canoy moved to dismiss the complaint and quash the writ of replevin.
The motion was denied on April 18, 1986.
A motion for reconsideration filed by Canoy was also denied on May 19, 1986, with the RTC ordering delivery of the vehicle to petitioner.

Respondents filed a Petition for Certiorari and Prohibition before the Court of Appeals (CA) to nullify the RTC Branch VIII’s orders dated April 18 and May 19, 1986.
Meanwhile, a criminal case for carnapping against petitioner was provisionally dismissed by the City Fiscal’s office, without prejudice to reopening after ownership issues are resolved.

On May 7, 1987, the CA reversed the RTC Branch VIII and nullified the questioned orders.
The CA held that only the court which issued the search warrant (Branch XIII) could order the release of the seized vehicle.
The CA dismissed the replevin action and restored possession to Canoy, applying the ruling in Pagkalinawan vs. Gomez (21 SCRA 1275 [1967]).

Petitioner filed a petition for review on certiorari under Rule 45 assailing the CA decision.
The Supreme Court took up the issue on whether validity of the seizure made pursuant to a search warrant can be questioned in a different branch of the same court.

Whether or not the validity of a seizure made pursuant to a search warrant issued by a court can be questioned in another branch of the same court, where the criminal action related to the search warrant was provisionally dismissed but subject to reopening once ownership issues are resolved.