Case Digest (G.R. No. 111267)
Facts:
Columbia Pictures Entertainment, Inc., et al. v. Honorable Court of Appeals, 14th Division and Jose B. Jingco of Showtime Enterprises, Inc., G.R. No. 111267, September 20, 1996, Supreme Court Second Division, Romero, J., writing for the Court. Petitioners are seven film companies that complained to the Videogram Regulatory Board (VRB) about alleged piracy; private respondent is Jose B. Jingco of Showtime Enterprises, Inc., and the other respondent is the Court of Appeals, 14th Division.An intelligence officer of the VRB, Alfredo G. Ramos, received information that private respondent possessed pirated videotapes and related paraphernalia. Ramos verified the information, filed a sworn application for a search warrant dated July 28, 1986, and testified at a same-day hearing before Judge Florentino A. Flor of the Regional Trial Court (RTC) of Pasig, Branch 168, together with two witnesses, Analie Jimenez and Rebecca Benitez-Cruz. Search Warrant No. 23 was issued on July 28, 1986 authorizing seizure of pirated videotapes, promotional materials, accounting records and equipment used or intended for unlawful sale or exhibition in violation of Presidential Decree No. 49, as amended.
On June 2, 1987 private respondent filed a Motion to Quash Search Warrant No. 23, arguing it was a general warrant and failed to specify a single offense; the VRB opposed, citing violation of Section 56 of PD 49. The RTC (Pasig) denied the Motion to Quash on September 30, 1987 and denied reconsideration. Private respondent later filed an Urgent Motion to Lift the Search Warrant and for Return of Seized Articles. On May 22, 1989, Judge Benjamin V. Pelayo of the RTC, Branch 168, granted that motion, finding lack of probable cause, and ordered return of the seized items; the Court of Appeals affirmed that order. Petitioners brought the present petition before the Supreme Court seeking reversal.
In the proceedings the Court considered whether petitioners had standing to file the petition; whether the Court’s earlier decision in 20th Century Fox Film Corporation v. Court of Appeals (162 SCRA 655, 1988) — which emphasized production of master tapes to establish probable cause — could be applied retroactively to quash a warrant issued in 1986; and whether Se...(Pro-only)
Issues:
- Do petitioners have legal personality and standing to prosecute this petition before the Supreme Court?
- May the Court’s 20th Century Fox ruling (promulgated August 19, 1988) be retroactively applied to quash a search warrant issued on July 28, 1986?
- Was Search Warrant No. 23 invalid for want of particularity or probable cause (i.e., a general warrant), such that the trial court’s orde...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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