Facts:

The case revolves around petitioner Ferdinand V. Tomas and respondents Criminal Investigation and Detection Group (CIDG) - Anti-Organized Crime Division (AOCD) and Myrna Uy Tomas. The events began when private respondent Myrna filed four complaints against Ferdinand V. Tomas, alleging violations of Sections 155 and 168, in relation to Section 170 of Republic Act No. 8293, known as the Intellectual Property Code of the Philippines. The complaints led the CIDG-AOCD to apply for search warrants on October 24, 2007, in the Regional Trial Court (RTC) of Manila. These applications, signed by P/Chief Inspector Helsin B. Walin and approved by Director Edgardo M. Doromal, Chief of the CIDG, resulted in the issuance of four search warrants. The authorities executed these search warrants at two locations in Urdaneta City, Pangasinan, where they confiscated various items related to trademark infringement. Petitioner Ferdinand V. Tomas challenged the validity of the search warrants through a

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Facts:

Background of the Case

• Ferdinand V. Tomas, petitioner, challenged prior judicial and prosecutorial actions arising from trademark infringement and unfair competition allegations under Republic Act No. 8293 (the Intellectual Property Code).
• Private respondent Myrna Uy Tomas filed four complaints charging violations under Sections 155 and 168 (in relation to Section 170) of the said law.
• The complaints were lodged against petitioner and other alleged co-conspirators, with two complaints involving multiple defendants and two targeting petitioner exclusively.

The Issuance and Execution of Search Warrants

• On October 24, 2007, the Philippine National Police – Criminal Investigation and Detection Group (CIDG), Anti-Organized Crime Division (AOCD) filed four separate applications for search warrants before the Regional Trial Court (RTC) of Manila.
• The applications were signed by Police Chief Inspector Helsin B. Walin and approved by Police Director Edgardo M. Doromal, though questions arose regarding the proper endorsement protocol required by administrative guidelines.
• The RTC, under Executive Judge Reynaldo G. Ros, issued Search Warrant Nos. A07-12100 to A07-12103, which were executed at premises in Urdaneta City, Pangasinan, resulting in the seizure of various Pedrollo-branded equipment and components.

Procedural Motions and Court Actions

• Petitioner filed a Motion to Quash the search warrants and/or suppress the evidence, contending that the applications were defective pursuant to SC Administrative Matter No. 03-8-02-SC because the applications lacked personal endorsement by the head of the agency (i.e., the then PNP Chief).
• On January 11, 2008, the RTC partially granted the motion by quashing certain warrants, but later, on April 16, 2008, after a motion for partial reconsideration by the respondents, the RTC reversed its earlier order.
• Petitioner then elevated the matter by filing a Petition for Certiorari with the Court of Appeals (CA) (docketed as CA-G.R. SP No. 104029), which scrutinized the reliance on the defective endorsement issue and the issuance of the search warrants.

Developments in the Court of Appeals and Allegations of Forum Shopping

• On August 16, 2011, the CA Sixth Division rendered a decision quashing Search Warrant Nos. A07-12100 to A07-12103, holding that the applications were defective under Section 12, Chapter V of A.M. No. 03-8-02-SC because they were not personally endorsed by the PNP Chief.
• Subsequently, petitioner filed a Petition for Review under Rule 43 (docketed as CA-G.R. SP No. 114479) against a Joint Resolution by the Secretary of Justice dated July 24, 2009, which found probable cause against him.
• The CA Fourth Division later reversed the earlier quashing by upholding the validity of the search warrants and the seizure of evidence, and it also addressed allegations of forum shopping, noting that petitioner had failed to satisfy the requirements against multiple filings involving substantially identical issues.

Submission of Certifications and Judicial Reasoning on Delegation

• Petitioner argued that the defect in the search warrant application was fatal because the personal endorsement requirement was not met at the time the application was made.
• The CA, however, held that the absence of the personal endorsement of the PNP Chief should only incur administrative liability and would not affect the warrant’s validity if the head had delegated his endorsement to a subordinate, a point clarified in previous jurisprudence.
• In addressing forum shopping, the CA found that petitioner had duly certified the pendency of his earlier petition when filing subsequent actions, though it maintained that the existence of identical parties and issues rendered the advisability of multiple applications questionable.

Issue:

• Whether the decision of the CA Fourth Division dated March 25, 2013, which upheld the validity of Search Warrant Nos. A07-12100 to A07-12103, violates the fundamental rule on the immutability of a final judgment, considering that a prior decision by the CA Sixth Division had already quashed the warrants.

• Whether the CA has the authority to effectively dismiss or modify a case (CA-G.R. SP No. 104029) that had reached finality, particularly regarding the issuance and validity of the search warrants, without violating the rule on finality of judgment.

• Whether reopening or amending a decision that has become final and executory (and which includes findings on issues such as forum shopping) is permissible, or whether it contravenes the doctrine of immutability of final judgments.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)