Case Summary (G.R. No. 83578)
RTC Proceedings and Orders
The RTC granted a five‐day temporary restraining order on March 13, 1985, and, after hearing, declared all six search warrants null and void on April 16, 1985. It ordered the return of all seized property and denied its own reconsideration on August 21, 1985.
Court of Appeals’ Initial Ruling
On certiorari, the Court of Appeals held that PADS Task Force, vested by PD 1936 with powers to investigate and prosecute foreign exchange violations, ranked with Regional Trial Courts. Thus, the RTC had no jurisdiction to quash its warrants, and its decisions were appealable only to the President.
Court of Appeals’ Reversals and Petitioner’s Contentions
Karamfil successfully moved for reconsideration, prompting CA resolutions (September 24, 1987, and May 20, 1988) that reversed the Court’s own October 1986 decision and denied PADS’s motion. PADS petitioned the Supreme Court, alleging grave abuse of discretion by the CA in:
a) Allowing the RTC to countermand PADS warrants despite coordinate status;
b) Engaging in judicial legislation and violating separation of powers;
c) Failing to address issues on warrant specificity, dual‐offense charging, and mootness.
Issues Presented
- Whether PADS Task Force is a quasi‐judicial body co‐equal with the Regional Trial Court, thus beyond RTC jurisdiction.
- Whether PADS qualifies as a “responsible officer” under the 1973 Constitution empowered to issue search and arrest warrants.
Nature, Jurisdiction, and Quasi‐Judicial Status
Quasi‐judicial bodies are government agencies, other than courts or legislatures, that adjudicate rights or set rules. Under the Judiciary Reorganization Act and the 1973 Constitution, decisions of quasi‐judicial agencies are appealable to higher courts, indicating they stand on par with Regional Trial Courts. To be co‐equal, a body must render final, binding decisions and exercise adjudicatory functions.
Mandate and Powers of the PADS Task Force
PD 1936 (as amended) grants PADS the power to investigate and prosecute dollar‐salting offenses, administer oaths, issue subpoenas, appoint personnel, and impose fines or administrative sanctions prior to filing charges. It lacks authority to render final judgments or execute rulings akin to a court.
Authority to Issue Warrants Under the 1973 Constitution
The 1973 Constitution reserves issuance of search and arrest warrants to judicial officers or “such other responsible officer as may be authorized by law.” Jurisprudence (Lim v. Ponce de Leon; Collector of Customs v. Villaluz; Ponsica v. Ignalaga) establishes that only an impartial judge or a truly neutral “responsible officer” may issue warrants. Prosecutors, inherently interested in secu
Case Syllabus (G.R. No. 83578)
Factual Background
- The Presidential Anti-Dollar Salting Task Force (PADS Task Force) was created under Presidential Decree No. 1936, as amended by P.D. No. 2002, to investigate and prosecute “dollar-salting” activities.
- On March 12, 1985, State Prosecutor Jose B. Rosales, acting for the Task Force, filed applications and secured six search warrants (Nos. 156–161) against various corporations, including Karamfil Import-Export Co., Inc.
- The supporting documents—an affidavit and a deposition—were prepared by Josefin M. Castro, an operative and investigator of the PADS Task Force, all dated March 12, 1985.
- Karamfil Import-Export Co., Inc. petitioned the Regional Trial Court (RTC), Branch 147, Makati, seeking to enjoin implementation of those search warrants.
Proceedings Before the Regional Trial Court
- March 13, 1985: The RTC issued a temporary restraining order effective for five days and scheduled a hearing for March 18, 1985.
- The RTC identified three material issues:
- Competency of the RTC to act on the petition.
- Validity of the search warrants issued by the State Prosecutor.
- Mootness, given that the search warrants had already been executed.
- April 16, 1985: The RTC declared Search Warrant Nos. 156–161 null and void and ordered the return of seized property.
- August 21, 1985: The RTC denied the Task Force’s motion for reconsideration of its April 16 Order.
Certiorari Before the Court of Appeals
- April 4, 1986: The PADS Task Force elevated the RTC’s twin orders to the Court of Appeals via petition for certiorari.
- October 24, 1986: The Court of Appeals initially ruled for the Task Force, holding that:
- The PADS Task Force is a special quasi-judicial body with powers akin to a Regional Trial Court under P.D. No. 1936.
- The RTC lacked jurisdiction to nullify the Task Force’s lawful writs.
- The Task Force’s decisions were appealable only to the Office of the President.
Reconsideration in the Court of Appeals
- November 12, 1986: Karamfil moved for reconsideration, challenging whether the PADS Task Force qualified as a “responsible officer” under the 1973 Constitution to issue warrants.
- September 24, 1987: The Court of Appeals granted Karamfil’s motion and reversed its October 24, 1986 D