Case Digest (G.R. No. 122092) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Paper Industries Corporation of the Philippines et al. v. Judge Maximiano C. Asuncion et al. (G.R. No. 122092, May 19, 1999), Police Chief Inspector Napoleon B. Pascua applied on January 25, 1995 before the Regional Trial Court (RTC), Branch 104, Quezon City, for Search Warrant No. 799(95) to search the PICOP compound in Barangay Tabon, Bislig, Surigao del Sur. He alleged that the management of Paper Industries Corporation of the Philippines, represented by its Senior Vice-President Ricardo G. Santiago, possessed high-powered firearms, ammunition and grenades in violation of Presidential Decree No. 1866. The application was supported by the joint deposition of SPO3 Cicero S. Bacolod and SPO2 Cecilio T. Morito, a summary of information and supplementary statements of two civilian informants. At the in camera hearing, only Bacolod appeared; Pascua did not personally affirm his application nor did other witnesses testify. On February 4, 1995, law enforcement officers executed th Case Digest (G.R. No. 122092) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition for Certiorari and Prohibition
- Petitioners sought nullification of Search Warrant No. 799 (95) and RTC Orders of March 23, 1995 and August 3, 1995, and prayed for a TRO against preliminary investigation IS No. 95-167.
- On October 23, 1995 the Supreme Court issued the TRO and required respondents’ comment.
- Respondents filed Opposition (Dec. 20, 1995); the Office of the Solicitor General agreed with petitioners; multiple resolutions followed requiring memoranda from State Prosecutor Dacera and the PNP SOU, who failed to comply.
- Application and Issuance of Search Warrant
- On January 25, 1995 P/Insp. Napoleon B. Pascua applied for Warrant No. 799 (95) against Paper Industries Corp. (PICOP) compound in Bislig, Surigao del Sur, alleging possession of firearms, ammunition and explosives, supported by:
- Joint deposition of SPO3 Cicero S. Bacolod and SPO2 Cecilio T. Morito.
- Summary of information and supplementary statements of informants Mario Enad and Felipe Moreno.
- Judge Maximiano C. Asuncion issued the warrant after examining SPO3 Bacolod under oath, authorizing a daytime search and seizure of specified weapons.
- Execution and Seizure
- On February 4, 1995 police executed the warrant, seizing dozens of firearms (M16s, M14s, AK-47s, UZIs, etc.), thousands of rounds of ammunition, hand grenades, magazines, and other war materials from various posts within the PICOP compound.
- Trial Court Proceedings
- Petitioners filed a Motion to Quash, Supplemental Pleading, and Motion to Suppress Evidence in RTC Branch 104, Quezon City.
- On March 23, 1995 and August 3, 1995 the RTC denied the motions and the motion for reconsideration.
- Petitioners elevated the matter to the Supreme Court.
Issues:
- Did the RTC judge abuse discretion or exceed jurisdiction in refusing to quash Search Warrant No. 799 (95) for lack of probable cause and general-warrant character?
- Did the judge abuse discretion in refusing to quash the warrant on grounds of unlawful service or implementation?
- Is State Prosecutor Dacera acting with grave abuse of discretion or exceeding jurisdiction by proceeding with IS No. 95-167 based on illegally seized evidence?
- Should the petition be dismissed for raising factual questions not cognizable under Rule 65?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)