G.R. No. 204419 - People vs. Castillo Sr.

On January 13, 2012, Judge Marcelo C. Cabalbag of the Municipal Trial Court (MTC) of Gattaran, Cagayan issued Search Warrant No. 45 after examining under oath SPO1 Ronel P. Saturno (Regional Intelligence Division, PDEA) and his witness, finding probable cause to believe a violation of R.A. 9165 (Comprehensive Dangerous Drugs Act) was being committed at the residence of Jeofrey Jil Rabino y Taloza in Aparri, Cagayan.
Philippine Drug Enforcement Agency (PDEA) and Philippine National Police (PNP) officers executed the warrant, seizing one sachet containing residue of suspected methamphetamine hydrochloride inside Rabino’s house. Laboratory examination confirmed the presence of methamphetamine hydrochloride (“shabu”).

On January 15, 2012, an Information was filed in the Regional Trial Court (RTC), Branch 6, Aparri, Cagayan, charging Rabino with Illegal Possession of Dangerous Drugs (Section 11, R.A. 9165), docketed as Criminal Case No. 11-10881.
Before arraignment, on March 13, 2012, Rabino filed a Motion to Quash the Search Warrant and for Suppression of Illegally Acquired Evidence, alleging, among others, lack of MTC jurisdiction, absence of probable cause, and failure to describe with particularity the place to be searched.

On May 14, 2012, RTC Branch 6, through Judge Edmar P. Castillo, Sr., granted the motion to quash, ruling that the MTC of Gattaran lacked jurisdiction—since the minimum penalty for the offense exceeded its jurisdictional threshold—and thus Search Warrant No. 45 was null and void. All evidence was suppressed and the Information dismissed.
The RTC denied the People’s motion for reconsideration on September 24, 2012. On November 12, 2012, the People of the Philippines, represented by the Second Assistant Provincial Prosecutor, filed a petition for certiorari under Rule 65 before the Supreme Court seeking to reverse and set aside the RTC’s resolution and reinstate Criminal Case No. 11-10881.

Whether a petition for certiorari under Rule 65 may be filed directly with the Supreme Court despite the hierarchy of courts, and whether the remedy is plain, speedy, and adequate.
Whether the Assistant Provincial Prosecutor, instead of the Office of the Solicitor General (OSG), is a proper party to file the petition.

Whether the MTC of Gattaran had authority under Rule 126, Section 2 of the Rules of Court to issue Search Warrant No. 45 for a dangerous drugs offense committed in the same judicial region but outside its territorial jurisdiction over the offense.
Whether the RTC judge gravely abused discretion in quashing the warrant solely on the ground that the MTC lacked trial jurisdiction over R.A. 9165 offenses.