Facts:

• The case involves the Petron LPG Dealers Association and Total Gaz LPG Dealers Association as petitioners.
• They filed a letter-complaint with the National Bureau of Investigation-Ilocos Regional Office (NBI-IRO) against respondents Nena C. Ang, Alison C. Sy, Nelson C. Ang, Renato C. Ang, and National Petroleum Corporation (Nation Gas).
• The complaint alleged illegal trading and underfilling of LPG products, violating Sections 2(a) and (c) of Batas Pambansa Blg. 33 (BP 33), as amended by Presidential Decree No. 1865.
• NBI-IRO, through agent Marvin de Jemil, conducted surveillance and test-buy operations.
• Applications for search warrants were filed before the Regional Trial Court (RTC) of Bauang, La Union.
• The RTC issued Search Warrant Nos. 2005-59 and 2005-60, served on December 8, 2005, at the Magsingal LPG refilling plant.
• Respondents filed a motion to quash the search warrants, citing lack of probable cause and personal knowledge by the NBI agents.
• The RTC granted the motion and quashed the search warrants, a decision later upheld by the Court of Appeals (CA).
• Petitioners sought review by the Supreme Court.

Issue:

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Ruling:

• The Supreme Court granted the petition, reversing and setting aside the CA's decision and resolution.
• The Court sustained the ...(Unlock)

Ratio:

• The Supreme Court held that the evidence presented by the petitioners was sufficient to establish probable cause for the issuance of the search warrants.
• Probable cause for a search warrant requires facts and circumstances that would lead a reasonably discreet and prudent person to believe that an offense has been committed and that the items sought are in the place to be searched.
• The surveillance and test-buy operations conducted by De Jemil and Antonio, along with the written certifications from LPG companies and the inspection results of the test-buy cylinder, provided a reasonable basis to believe that the respondent...continue reading