Case Digest (G.R. No. 257683)
Facts:
Jimmy B. Puguon, Jr. v. People of the Philippines, G.R. No. 257683, October 21, 2024, the Supreme Court Third Division, Gaerlan, J., writing for the Court.On July 2, 2019, Branch 31 of the Regional Trial Court (RTC) of Cabarroguis, Quirino issued Search Warrant No. 0015-2019 directing law enforcement to search the house of Jimmy B. Puguon, Jr. and seize listed firearms, ammunition and two hand grenades. Execution of the warrant led to the filing of two separate Informations against Puguon: Criminal Case No. 3901-2019 for alleged violations of Republic Act No. 10591 (Comprehensive Firearms and Ammunition Regulation Act) and Criminal Case No. 3902-2019 for alleged violation of Republic Act No. 9516 (amending provisions of P.D. No. 1866 concerning explosives).
Puguon moved in the RTC to quash the search warrant, suppress evidence and dismiss the Informations, arguing the warrant was a scatter-shot warrant that covered two distinct special offenses and therefore violated his constitutional right against unreasonable searches and seizures. The provincial prosecutor and later the Office of the Solicitor General (OSG) opposed, contending the two statutes are related and that the search warrant was valid, relying on precedents such as Prudente v. Dayrit and People v. Pastrana.
On September 6, 2019, the RTC denied Puguon’s motion and, on November 21, 2019, denied his motion for reconsideration. Puguon sought relief from the Court of Appeals (CA) by a Rule 65 certiorari petition alleging grave abuse of discretion by the RTC. The CA, in a Decision dated June 30, 2021 (CA-G.R. SP No. 164326), denied the petition, holding that the warrant was valid because the offenses involved were of the same class and similar in nature.
Puguon filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court challe...(Subscriber-Only)
Issues:
- Did Search Warrant No. 0015-2019 violate petitioner Jimmy B. Puguon, Jr.’s constitutional right against unreasonable searches and seizu...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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