G.R. No. 253450 - Nayve-Pua vs. Union Bank of the Philippines

On March 31, 2015, Police Superintendent Jaycees De Sagun Tolentino (Tolentino) filed two separate applications for search warrants before the Regional Trial Court (RTC) of Calapan City, Branch 40.
The applications targeted Stanley Maderazo (Maderazo), Nestor Alea, Daren Mabansag, and Lovely Joy Alcantara based on information from barangay officials Loida Tapere Roco (Roco) and Rexcel Lozano Rivera (Rivera).
Roco and Rivera informed that Maderazo and others kept dangerous drugs, drug paraphernalia, firearms, and ammunition inside the residence in Barangay Lazareto, Calapan City.
Roco and Rivera stated that at 6:00 AM on March 31, 2015, they learned the police would serve an arrest warrant on Maderazo for attempted murder. Upon arrival, Maderazo was already arrested. They interviewed him, and he allegedly admitted to possessing approximately 40 grams of illegal drugs, drug paraphernalia, and a firearm inside the house.
Tolentino claimed to have verified this information through casing and surveillance.

On March 31, 2015, after a preliminary investigation under oath of Roco and Rivera, Executive Judge Tomas C. Leynes issued Search Warrant Nos. 09-2015 for violation of R.A. No. 9165 (dangerous drugs law) and 10-2015 for violation of R.A. No. 10591 (illegal possession of firearm).
Both search warrants were served on the same day at the residence in Barangay Lazareto.
Police recovered heat-sealed transparent plastic sachets suspected to contain shabu, drug paraphernalia, a .38 caliber revolver, live ammunition, mobile phones, a laptop, and cash.
Maderazo, Alea, and Mabansag were charged with illegal possession of dangerous drugs and paraphernalia, and illegal possession of firearms, respectively.

On July 1, 2015, Maderazo filed a Motion to Quash, arguing no probable cause existed for issuing the search warrants.
He asserted Tolentino had no personal knowledge and relied solely on hearsay from Roco and Rivera, whose information was based on Maderazo’s own admission.
Maderazo claimed Tolentino’s alleged casing and surveillance were impossible because Maderazo was under police custody, and the house was cordoned off at that time.
He requested the certified true copy of the Transcript of Stenographic Notes (TSN) of the preliminary investigation but was only given copies of substantially identical sworn statements of Roco, Rivera, and caretaker Sally Cueto.
On August 14, 2015, the RTC denied the Motion to Quash for lack of merit. Reconsideration was also denied on September 21, 2015.

Maderazo filed a petition for certiorari before the CA, alleging grave abuse of discretion by the trial court in denying the motion to quash.
On April 26, 2017, the CA granted the petition, nullified Search Warrant Nos. 09-2015 and 10-2015, and ruled that items seized under these were inadmissible as the search warrants were void.
The CA held that there was no probable cause as Tolentino and witnesses did not have personal knowledge, and the trial judge failed to conduct a probing and exhaustive examination.

The People of the Philippines (petitioner) assailed the CA ruling, claiming the trial judge had personal examination of witnesses and had sufficient basis for probable cause.
The Solicitor General argued the statements were sworn records of the hearing, and Maderazo’s admission constituted probable cause.

Whether the Court of Appeals erred in ruling that the RTC judge committed grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the Orders denying the Motion to Quash the search warrants.
Whether the issuance of Search Warrant Nos. 09-2015 and 10-2015 was supported by probable cause based on personal knowledge of the applicant and his witnesses through a probing and exhaustive examination by the judge.
Whether items seized pursuant to the search warrants are admissible as evidence against Maderazo.