Case Digest (G.R. No. 137823) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The World Health Organization and Dr. Leonce Verstuyft vs. Hon. Benjamin H. Aquino, G.R. No. L-35131, decided on November 29, 1972 under the 1935 Constitution, petitioners WHO and Dr. Leonce Verstuyft challenged the issuance and refusal to quash Search Warrant No. 72-138 by Judge Aquino of the Court of First Instance of Rizal. Dr. Verstuyft, Acting Assistant Director of Health Services at WHO’s Manila Regional Office, arrived on December 6, 1971 and imported twelve crates of personal effects on January 10, 1972 as unaccompanied baggage duly exempted from duties under the Host Agreement of July 22, 1951. Respondents Major Wilfredo Cruz, Major Antonio G. Relleve, and Captain Pedro S. Navarro of COSAC applied for a warrant on March 3, 1972 to seize allegedly “highly dutiable goods” discovered in two crates—120 bottles of foreign wine and 15 tins of PX goods—and suspected contraband in the remaining ten. Despite a formal Citygram by Secretary Romulo and a comment by the Solicitor Case Digest (G.R. No. 137823) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and nature of action
- Petitioners: World Health Organization (WHO) and Dr. Leonce Verstuyft, Acting Assistant Director of Health Services, Manila.
- Respondents: Hon. Benjamin H. Aquino (Presiding Judge, Branch VIII, CFI Rizal) and COSAC officers (Major Wilfredo Cruz, Major Antonio G. Relleve, Captain Pedro S. Navarro).
- Relief sought: Writs of certiorari and prohibition to quash a search warrant and enjoin further proceedings.
- Factual and procedural background
- January 10, 1972 – Dr. Verstuyft’s personal effects in twelve crates arrived as unaccompanied baggage, admitted duty‐free under the 1951 Host Agreement; crates stored at Eternit warehouse pending relocation.
- March 3, 1972 – COSAC officers applied for, and respondent judge issued, Search Warrant No. 72-138 under RA 4712 (amending Tariff and Customs Code) to search and seize allegedly dutiable goods in ten crates.
- March 6, 1972 – Secretary Romulo wire‐notified the trial court of Dr. Verstuyft’s diplomatic immunity and requested suspension pending clarification; hearing set for March 16.
- March 16, 1972 – Trial court heard the plea but maintained the warrant despite diplomatic immunity claim.
- March 24 & April 12, 1972 – Dr. Verstuyft’s special appearance and motion to quash filed; May 8 hearing, Solicitor General filed comment affirming immunity; May 9 order denied quashal.
- June 6, 1972 – Supreme Court issued temporary restraining order; memoranda filed by respondents (Aug. 3) and petitioners (Aug. 21); case deemed submitted.
Issues:
- Whether the trial court acted without jurisdiction and with grave abuse of discretion in issuing and maintaining a search warrant against a duly accredited WHO official enjoying diplomatic immunity.
- Whether judicial search and seizure is a proper remedy for alleged abuses of diplomatic immunity, given treaty obligations and the principle of separation of powers.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)