Case Digest (G.R. No. 83578) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On March 12, 1985, State Prosecutor Jose B. Rosales of the Presidential Anti-Dollar Salting Task Force (PADS Task Force) procured Search Warrants Nos. 156–161 from a judge, based on an application by Atty. Napoleon Gatmaytan (a deputized Bureau of Customs member) supported by the affidavit and deposition of Task Force operative Josefin M. Castro. The next day, private respondent Karamfil Import-Export Co., Inc. filed a petition in the Regional Trial Court (Branch 147, Makati) to enjoin execution of those warrants. The RTC issued a temporary restraining order effective for five days and set a hearing for March 18, 1985. On April 16, 1985, the RTC declared the search warrants null and void and ordered the return of all seized properties. A motion for reconsideration was denied on August 21, 1985. On April 4, 1986, the PADS Task Force elevated the matter to the Court of Appeals via certiorari. In its October 24, 1986 Decision, the CA set aside the RTC orders, holding that the Task Case Digest (G.R. No. 83578) Expanded Legal Reasoning Model
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)