Facts:

• Petitioners Kenneth Roy Savage and K Angelin Export Trading, managed by Gemma Demoral-Savage, sought to nullify a search warrant.
• The warrant was issued by Judge Aproniano B. Taypin of the Regional Trial Court (RTC), Branch 12, Cebu City, on October 16, 1997.
• The warrant authorized the National Bureau of Investigation (NBI) to search K Angelin Export International in Talisay, Cebu, based on a complaint from Eric Ng Mendoza of Mendco Development Corporation (MENDCO).
• The complaint alleged unfair competition involving design patents, a violation under Article 189 of the Revised Penal Code.
• The search was executed on October 17, 1997, resulting in the seizure of wrought iron furniture claimed to be involved in unfair competition.
• Petitioners filed a motion to quash the search warrant on October 30, 1997, citing lack of probable cause and failure to properly describe seized items.
• A Supplemental Motion to Quash was filed, arguing the absence of a certification against forum shopping.
• Both motions were denied by the RTC on January 30, 1998, and a subsequent motion for reconsideration was also denied.
• Petitioners then sought relief from the Supreme Court through a petition for certiorari.

Issue:

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Ruling:

• The Supreme Court ruled in favor of the petitioners, nullifying the search warrant issued by the RTC.
• The Court set aside the RTC's orders denying the motions to quash and for reconsideration....(Unlock)

Ratio:

• The RTC had jurisdiction to issue the search warrant, as all courts have inherent authority to do so, not limited to special courts for Intellectual Property Rights (IPR).
• The designation of special courts under Supreme Court Administrative Order No. 113-95 does not prevent other courts from exercising their jurisdiction to issue search warrants.
• The absence of a certification against forum shopping was not a valid ground for dismissing the application, as current Rules of...continue reading