Facts:

The case involves Nestor Ilano as the petitioner against the Court of Appeals, Hon. Maximiano C. Asuncion, Presiding Judge of the Regional Trial Court (RTC) of Quezon City, Br. 104, Hon. Antonio J. Fineza, Presiding Judge of the RTC of Kalookan City, Br. 131, and the People of the Philippines as respondents. The events leading to the case began when the Philippine National Police - Narcotics Command (PNP-NARCOM), through 1Lt. Josephus Angan, applied for a search warrant before the RTC of Kalookan City to search Ilano's residence and parlor located at No. 7 and 9 Masigasig Street, Barangay Pinahan, Quezon City, Metro Manila. On January 31, 1991, after examining the application and witness, Judge Antonio J. Fineza issued Search Warrants Nos. 1-017-91 (NCR) and 1-018-91 (NCR). The subsequent search yielded various illegal substances, including marijuana, shabu, and paraphernalia. Following the search, an Information was filed against Ilano for violating the Dangerous Drugs A...

Facts:

1. Background of the Case:

   • Petitioner Nestor Ilano sought to nullify search warrants issued by the Regional Trial Court (RTC) of Kalookan City, Metro Manila, which authorized the search of his house and parlor in Quezon City, Metro Manila.
   • The search warrants were issued based on an application by the PNP-NARCOM, National Capital Region, through 1Lt. Josephus Angan.

2. Search and Seizure:

   • The search yielded the following items:
     • One (1) stick of suspected marijuana cigarette.
     • Two (2) tablets of suspected mogadon.
     • One (1) aluminum foil containing shabu residue.
     • One (1) improvised tooter used in administering shabu.
     • Approximately fifteen (15) grams of suspected shabu wrapped in three (3) separate transparent plastic bags.

3. Legal Proceedings:

   • An Information was filed against Ilano for violation of Sec. 16, Art. III, R.A. 6425 (Dangerous Drugs Act of 1972, as amended) before the RTC of Quezon City.
   • Ilano filed a Motion for Leave of Court to File Reinvestigation, claiming newly discovered material evidence. This motion was denied.
   • He later filed a Motion to Suppress Evidence and Suspend Hearing, challenging the validity of the search warrants. This motion was also denied.
   • Ilano elevated the case to the Court of Appeals via certiorari, which denied his petition.

4. Petitioner’s Arguments:

   • Ilano argued that the RTC of Kalookan City had no jurisdiction to issue search warrants for a location outside its territorial jurisdiction (Quezon City).
   • He relied on Circular No. 19, which states that applications for search warrants should be filed in the court with jurisdiction over the place to be searched.
   • He also claimed that the denial of his motions amounted to a denial of his right to a preliminary investigation and due process.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction to Issue Search Warrants:

   • The issuance of a search warrant is an exercise of ancillary jurisdiction and is not confined to the territorial jurisdiction of the issuing court.
   • Circular No. 19 is not a general rule but an emergency guideline applicable only to specific crimes and courts with multiple salas.

2. Due Process and Preliminary Investigation:

   • The denial of a motion for reinvestigation and a motion to suppress evidence does not equate to a denial of due process, especially when a preliminary investigation has already been conducted.
   • The trial court has discretion to deny such motions, particularly when they are filed belatedly and seek to revisit evidence already considered during the preliminary investigation.