Washington Distillers, Inc. v. Court of Appeals

G.R. No. 118151 (August 22, 1996)

RTC quashed search warrant for jurisdiction; CA reversed, SC reinstated, stressing legal procedure.

Facts:

Petitioner Washington Distillers, Inc., owned by Manuel Co Kehyeng and his family, is a domestic corporation based in San Fernando, Pampanga, engaged in the manufacture of liquor products. The company used 350cc round white flint bottles marked with the names of La TondeAa Distillers, Inc. and Ginebra San Miguel, which are registered trademarks under Republic Act No. 623. La TondeAa, a competitor in the liquor industry, filed a complaint with the National Bureau of Investigation (NBI) alleging that Washington Distillers was illegally using its registered bottles.

On May 20, 1993, La TondeAa requested the NBI to assist in prosecuting illegal users of its registered bottles. Following surveillance operations, NBI agents, accompanied by La TondeAa's legal counsel, entered Washington Distillers' premises and discovered a large quantity of the disputed bottles. Based on the findings, NBI Agent Dante J. Jacinto applied for a search warrant, which was granted by Judge Rosalio G. de la Rosa of the Regional Trial Court (RTC) of Manila. The NBI subsequently seized 314,289 bottles from Washington Distillers on May 26-27, 1993.

Washington Distillers filed a motion to quash the search warrant, arguing that the RTC of Manila lacked jurisdiction to issue a warrant for execution in Pampanga and that there was no probable cause for the warrant's issuance. They also claimed that La TondeAa was guilty of forum shopping, having previously sought similar warrants in Pampanga courts.

On August 31, 1993, Judge Antonio L. Descallar, acting as an assisting judge, granted the motion to quash, ruling that the RTC of Manila had no authority to issue a search warrant effective outside its jurisdiction and that La TondeAa had engaged in forum shopping. La TondeAa filed a petition for certiorari with the Court of Appeals, which reversed the RTC's order, leading to the present appeal.

Legal Issues:

  1. Did the RTC of Manila have jurisdiction to issue a search warrant enforceable in Pampanga?
  2. Was La TondeAa guilty of forum shopping in its application for the search warrant?
  3. Did Judge Descallar have the authority to quash the search warrant issued by Judge de la Rosa?
  4. Was La TondeAa entitled to maintain possession of the seized bottles despite the lack of a pending criminal case?

Arguments:

Petitioners' Arguments:

  • The RTC of Manila lacked jurisdiction to issue a search warrant for execution outside its territorial jurisdiction.
  • La TondeAa was guilty of forum shopping, having previously sought similar warrants in Pampanga courts.
  • The search warrant was invalid due to the absence of a pending criminal case against them, and thus the seized bottles should be returned.

Respondent's Arguments:

  • La TondeAa contended that it had the right to file a petition for certiorari as the party that requested the search warrant.
  • The search warrant was valid as it was issued under the authority of the executive judge, and the NBI acted within its mandate to enforce the law regarding trademark violations.

Court's Decision and Legal Reasoning:

The Supreme Court reversed the decision of the Court of Appeals, reinstating the orders of the RTC. The Court held that:

  1. Jurisdiction: The RTC of Manila did not have the authority to issue a search warrant enforceable outside its jurisdiction. This was consistent with the ruling in Malaloan v. Court of Appeals, which clarified that search warrants must be executed within the territorial limits of the issuing court.

  2. Forum Shopping: The Court found that La TondeAa had indeed engaged in forum shopping by seeking a search warrant from the Manila RTC after previously applying for similar warrants in Pampanga courts. This practice undermines the integrity of judicial proceedings and is prohibited.

  3. Authority of Judge Descallar: The Court affirmed that Judge Descallar, as an assisting judge, had the authority to quash the search warrant issued by Judge de la Rosa. The jurisdiction of the court is not limited to the individual judge, and an assisting judge can revoke orders of another judge in cases assigned to him.

  4. Possession of Seized Bottles: The Court ruled that the search warrant proceedings could not be used as a means for La TondeAa to acquire possession of the bottles without a proper legal action. Since no criminal case was filed following the seizure, the bottles should be returned to Washington Distillers.

Significant Legal Principles Established:

  • The jurisdiction of a court to issue search warrants is limited to its territorial boundaries.
  • Forum shopping is prohibited in search warrant proceedings, as it can lead to conflicting judicial decisions and undermine the legal process.
  • An assisting judge has the authority to quash a search warrant issued by another judge within the same court.
  • The seizure of property through a search warrant does not confer ownership or possession to the party requesting the warrant without a corresponding legal action.