G.R. No. 149554 - Spouses Huguete vs. Spouses Embudo

On June 24, 2015, RTC Branch 42, Virac, Catanduanes (Presiding Judge Lelu P. Contreras) issued Search Warrant No. 2015-45 for violations of RA 9165 (Comprehensive Dangerous Drugs Act) based on examinations under oath of PO1 Domingo Bilaos (applicant) and an unnamed confidential informant, alleging petitioner Rafael Zafe III a.k.a. “Pait” possessed “shabu” in his residence at Brgy. Sta. Cruz, San Andres, Catanduanes.
The warrant authorized day-or-night search of the person, residence, premises, and seizure of illegal drugs, paraphernalia, equipment, and was served the same day. Police seized shabu, paraphernalia, and ten live M-16 rounds. Rafael and spouse Cherryl were arrested and underwent inquest on June 16, 2015; probable cause was found for RA 9165 Sec. 12 and RA 10591 Sec. 28(g).

Criminal Cases Nos. 5524–5525 were filed on June 25, 2015, charging petitioners with possession of drug paraphernalia and live ammunition. Petitioners discovered that the search warrant’s supporting records (examinations of applicant and informants) were not in court records.
Petitioners moved for production of examination records (with redaction of identities). RTC denied the motion on September 2, 2015, citing protection of informants and public welfare; reconsideration was denied. Petitioners filed a certiorari petition with CA on December 1, 2015.
On August 31, 2016, the CA Special First Division denied the petition, deferring to the RTC’s factual findings and upholding the warrant’s validity. Petitioners elevated the case to the SC via Petition for Review on Certiorari.

Whether the Court of Appeals erred in denying due course to petitioners’ certiorari petition and affirming the RTC’s refusal to produce the search warrant’s supporting documents, and whether protecting confidential informant identities may override the accused’s due process rights and right against unreasonable search and seizure.
Whether petitioners should have been granted injunctive relief (temporary restraining order or injunction) to enjoin the ongoing criminal proceedings.