Case Digest (G.R. No. 257683)
Facts:
This case involves petitioner Jimmy B. Puguon, Jr. and the People of the Philippines. On July 2, 2019, the Regional Trial Court (RTC) of Cabarroguis, Quirino, issued Search Warrant No. 0015-2019 against Puguon following the sworn examination of Police Major Michael DG Bautista and three deponents, based on probable cause that Puguon violated Republic Act No. 10591, the Comprehensive Firearms and Ammunition Regulation Act. The warrant authorized the search and seizure of a variety of firearms and explosives, including one M16 rifle, one .45 pistol, one .38 revolver, two hand grenades, and related ammunition from Puguon's residence in Barangay Rizal, Diffun, Quirino. Subsequent to the search, two criminal cases were filed against Puguon: Criminal Case No. 3901-2019 for violation of RA 10591, and Criminal Case No. 3902-2019 for violation of RA 9516, which amends Presidential Decree No. 1866 concerning explosives. Puguon filed a motion to quash the search warrant, claiming it was aCase Digest (G.R. No. 257683)
Facts:
- Petition for Review and Background
- Petitioner Jimmy B. Puguon, Jr. filed a Rule 65 Petition for Certiorari under Rule 45 challenging the Court of Appeals (CA) Decision denying his motion to quash a search warrant.
- The search warrant (No. 0015-2019) was issued by the Regional Trial Court (RTC) Branch 31, Cabarroguis, Quirino, dated July 2, 2019, authorizing seizure of firearms, ammunition, and hand grenades from Puguon's house.
- Execution of this warrant led to two criminal cases against Puguon for violations of (a) Republic Act (RA) 10591 (Comprehensive Firearms and Ammunition Regulation Act) and (b) RA 9516 (amending provisions of Presidential Decree No. 1866 on illegal possession of explosives).
- Proceedings in the RTC
- Puguon filed an Omnibus Motion to Quash the Search Warrant, Suppress Evidence, and Dismiss the criminal cases, arguing the warrant was a "scatter-shot" warrant covering two distinct offenses under different laws.
- The prosecutor contended the warrant was valid since RA 10591 and RA 9516 originated from the same law, Presidential Decree No. 1866, and cited jurisprudence (People v. Pastrana, Prudente v. Dayrit) to support the validity of one warrant covering related offenses.
- The RTC denied the motion, holding the illegal possession of firearms, ammunition, and explosives belonged to the same class of offenses and thus one warrant was proper.
- Puguon's motion for reconsideration was denied by the RTC.
- Proceedings in the Court of Appeals
- Puguon filed a Rule 65 petition with the CA, asserting that RA 10591 expressly repealed parts of Presidential Decree No. 1866, thus the offenses under RAs 10591 and 9516 were distinct.
- The CA, relying on Prudente, held that RA 10591 and RA 9516 only amended penalties but did not change the offenses' nature and affirmed the RTC ruling.
- Present Petition for Review
- Puguon reiterates that the search warrant covered two separate offenses under two laws, violating the constitutional protection against unreasonable searches and seizures.
Issues:
- Whether Search Warrant No. 0015-2019 violated the constitutional right against unreasonable searches and seizures by covering two distinct offenses under separate laws, making it a scatter-shot warrant.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)