Title
Presidential Anti-Dollar Salting Task Force vs. Court of Appeals
Case
G.R. No. 83578
Decision Date
Mar 16, 1989
The PADS Task Force, lacking quasi-judicial authority, cannot issue search warrants; Supreme Court upheld separation of powers and constitutional safeguards.

Case Digest (G.R. No. 83578)
Expanded Legal Reasoning Model

Facts:

  • Creation and Powers of the Presidential Anti-Dollar Salting Task Force
    • Established by Presidential Decree No. 1936 (as amended by P.D. 2002) to investigate and prosecute “dollar-salting” activities (overvaluation of imports, undervaluation of exports).
    • Empowered to administer oaths, summon witnesses, issue subpoenas, impose fines or sanctions, punish contempts, and, notably, issue warrants of search and seizure.
  • Factual and Procedural History
    • On March 12, 1985, State Prosecutor Jose B. Rosales, for the Task Force, issued search warrants Nos. 156–161 against Karamfil Import-Export Co., Inc., et al., based on an application by Atty. Napoleon Gatmaytan and the affidavit/deposition of investigator Josefin M. Castro.
    • Karamfil filed a petition in the RTC (Branch 147, Makati) to quash the warrants; on March 13, 1985, the RTC issued a TRO and set hearing for March 18.
    • On April 16, 1985, the RTC declared the warrants null and void and ordered return of seized property; on August 21, 1985, it denied reconsideration.
    • On April 4, 1986, the Task Force sought certiorari relief in the Court of Appeals (CA); on October 24, 1986, the CA reversed the RTC, holding the Task Force a quasi-judicial body co-equal with the RTC.
    • Karamfil moved for reconsideration in the CA (Nov. 12, 1986); on September 24, 1987, the CA granted it and, on May 20, 1988, denied the Task Force’s motion, thereby reinstating the RTC’s orders.
    • The Task Force petitioned the Supreme Court to annul the CA resolutions for grave abuse of discretion and excess jurisdiction.

Issues:

  • Is the Presidential Anti-Dollar Salting Task Force a quasi-judicial body co-equal in rank with the Regional Trial Court, thereby beyond the latter’s jurisdiction?
  • May the Task Force, as a “responsible officer” under the 1973 Constitution, validly be delegated the power to issue search and arrest warrants?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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