A.M. No. RTJ 98-1420 - Office of the Court Administrator vs. Barron

Case Summary (A.M. No. RTJ 98-1420)

Facts of the Case

An Information for robbery was filed against respondents for allegedly taking cash amounting to ₱6,500,000.00, 286 postdated checks valued at over ₱4.3 million, boxes of Hennessy Cognac, and other items from Guan Yiak Hardware in Manila. The alleged robbery involved forcible entry, violence, intimidation, and the use of firearms at the Guan Yiak Hardware office in Binondo, Manila, on or about April 15, 2003. Police Inspector Edgar A. Reyes filed two separate applications for search warrants to recover the suspected stolen property believed to be in the possession of respondent Felicidad Chan Sy at 524 T. Pinpin Street, Binondo.

Issuance of Search Warrants

The Regional Trial Court (RTC) Manila, Branch 7, presided by Judge Enrico A. Lanzanas, conducted a hearing on April 22, 2003, personally examining the complainant and witnesses under oath. Based on their sworn statements and testimonies, Judge Lanzanas issued two search warrants directing peace officers to search specific floors of the building for five boxes of Hennessy XO and various company checks. The execution of the first warrant recovered twelve and seven Hennessy XO cognac bottles in boxes, while the second search yielded no items.

Procedural History

Respondents filed a Motion to Quash the search warrants, which the RTC denied on September 1, 2003, upheld upon reconsideration on October 28, 2003. Respondents then petitioned the Court of Appeals (CA) through a Rule 65 petition, arguing that the RTC judge abused discretion in denying the motion to quash due to lack of probable cause. The CA reversed the RTC decisions, granted the motion to quash on the grounds that probable cause was absent, and thus invalidated the search warrants. The petitioner filed a motion for reconsideration which the CA denied.

Issues Presented

The fundamental issue concerns whether probable cause existed to justify the issuance of the search warrants by the RTC.

Legal Framework on Search Warrants

Under Rule 126 of the Rules of Court, a search warrant may be issued only upon a judge’s personal determination of probable cause after examining the complainant and witnesses under oath. The warrant must particularly describe the place to be searched and the items to be seized. The power to issue search warrants is an exercise of judicial discretion subject to procedural safeguards and constitutional protection against unreasonable searches and seizures under the 1987 Philippine Constitution.

Court of Appeals’ Analysis and Ruling

The CA found that the RTC failed to prove probable cause, despite compliance with formal requirements like personal examination and particular description of the search targets. The CA considered the submissions and testimonies made by the petitioner and his witnesses to be insufficient to establish probable cause that a crime had occurred and that the searched items were connected to the offense.

Supreme Court’s Findings

The Supreme Court reversed the CA’s decision and reinstated the RTC orders and the validity of the search warrants. It emphasized that probable cause requires only facts and circumstances that would lead a reasonably prudent person to believe a crime has been committed and that evidence related to that crime would be found in the location subject to the search. Absolute or moral certainty is not required at this stage.

The Court highlighted that:

The RTC judge conducted thorough, searching questions personally to determine probable cause based on personal knowledge and sworn statements (Sinumpaang Salaysay) of the complainant and witnesses.
The evidence showed coordinated movement of the respondents and others in possession of the stolen goods, including five boxes of Hennessy XO and company checks.
The presence of police officers accompanying respondents and the context of forcible taking supported the belief that robbery had occurred.
The Judiciary is vested with exclusive authority to issue search warrants and is afforded discretion in determining probable cause, which this Court will not disturb unless there is grave abuse of discretion amounting to lack or excess of jurisdiction.
The nature of probable cause is based on probability and reasonable belief, not proof beyond reasonable doubt.

Legal Principles Applied

A search warrant must rest on probable cause determined personally by the judge.
Probable cause exists when sufficient facts and circumstances justify the belief that a crime has been committed and the items sought are connected to the offense and in the place to be searched.
A Rule 65 petitio

Case Syllabus (A.M. No. RTJ 98-1420)

Case Background and Procedural History

The case involves a Petition for Review on Certiorari seeking to annul and set aside a decision dated December 29, 2005, and a resolution dated August 18, 2006, both issued by the Court of Appeals (CA).
An Information for the crime of robbery was filed against respondents, including Felicidad Chan Sy and others, for alleged unlawful taking of ₱6,500,000.00 cash, 286 postdated checks, five boxes of Hennessy Cognac, a television set, a computer set, and other documents from Guan Yiak Hardware.
The robbery was alleged to have occurred on or about April 15, 2003, in Manila, with the accused forcibly entering the Guan Yiak Hardware’s office while armed and carrying away the items valued at approximately ₱11,135,642.00.
Police Inspector Edgar A. Reyes filed two separate applications for search warrants directed to search specific premises located at 524 Tomas Pinpin Street, Binondo, Manila, corresponding to the 7th and 8th floors for the items allegedly taken.
Judge Enrico A. Lanzanas of the Regional Trial Court, Manila, personally examined complainants and witnesses on April 22, 2003, issued Search Warrant Nos. 03-3611 and 03-3612, which were later served the same day.
The search under Warrant No. 03-3611 yielded some boxes containing Hennessy XO, while Warrant No. 03-3612 resulted in no findings.
Respondents filed a Motion to Quash the search warrants, which was denied by the RTC, and subsequently denied on reconsideration.
Respondents elevated the case to the Court of Appeals via Petition for Certiorari under Rule 65, arguing grave abuse of discretion and lack of probable cause for the issuance of the search warrants.
The CA granted the petition and set aside the RTC orders, declaring there was no probable cause justifying the issuance of the warrants.
Petitioner filed a motion for reconsideration with the CA, which was denied.
Petitioner then filed the present petition before the Supreme Court assailing the CA’s rulings.

Facts and Evidence Presented

The Information alleges a highly organized and forceful taking of cash, checks, and valuable items from Guan Yiak Hardware’s vault and premises by respondents and accomplices.
The applications for the search warrants were supported by sworn statements (Sinumpaang Salaysay) of Romer Sy Tan (petitioner) and witnesses Maricho Sabelita and Anicita Almedilla.
During the hearing for the issuance of the warrants, the RTC judge posed searching questions to the applicant and witnesses, eliciting facts indicating the presence of the stolen items at specified locations within 524 T. Pinpin St., Binondo.
The testimonies, consisting of at least 37 pages of Transcript of Stenographic Notes, reflected knowledge that the respondents, along with policemen, were found with the five boxes of Hennessy XO and checks.
Respondents’ entrance with two policemen puzzled the petitioner and rendered him unable to intervene during the incident.
The total value of the allegedly seized or taken items was ₱11,135,642.00, including cash, postdated checks worth ₱4,325,642.00, five boxes of Hennessy XO valued at ₱240,000.00, a television set, a computer, and other documents belonging to Guan Yiak Hardware.

Legal Issues

The primary legal issue was whether there was probable cause to justify the issuanc