2016

1. GR No. 181387, Sep 05, 2016

CAMERON GRANVILLE 3 ASSET MANAGEMENT vs.
UE MONTHLY ASSOCIATES

FACTS
Petitioner Cameron Granville 3 Asset Management, substitute plaintiff for Metrobank
who instituted a third-party claim before the Labor Arbiter during the pendency of
execution of judgment rendered by the latter, involving properties owned by UE
Automotive Manufacturing, Inc. (UEAMI) which were subjected to levy on execution
pursuant to a NLRC judgment in an illegal dismissal case, in which it was ordered to pay
P53,729,534 to complainants, herein respondents, UEAMI Monthly Associates and UE
Automotive Workers Union-NFL.

In its argument, petitioner claims that they were not afforded due process when they were
denied the opportunity to have a formal hearing to support its third-party claim.

ISSUE

Whether or not petitioner was denied due process in asserting his third-party claim.

RULE

We [likewise] find no merit in the assertion that petitioner was denied

due process. The decision of the LA (Labor Arbiter) not to conduct a formal evidentiary
hearing before resolving the case was justified, as the conduct of those hearings is not
mandatory in all instances, particularly in administrative proceedings. At its core, due
process simply means giving both parties a fair and reasonable opportunity to be heard
or to explain their side of the controversy.

Further, it must be pointed out that third-party claimants in execution

proceedings have the burden of proving their right or title to the subject
properties, if they want to defeat the judgment lien. To do so, they must submit evidence
not only of the basis of their entitlement, but also of the fact that the properties they are
claiming were indeed the subject of the execution. Failure to submit that evidence will
justify the denial of the third-party claim, as in this case.
2. G.R. No. 209330
SECRETARY LEILA DE LIMA, ASSISTANT STATE PROSECUTOR STEWART ALLAN
A. MARIANO, ASSISTANT STATE PROSECUTOR VIMAR M. BARCELLANO and
ASSISTANT STATE PROSECUTOR GERARD E. GAERLAN, Petitioners,
vs.
MARIO JOEL T. REYES, Respondent.

FACTS
Herein petitioner is the Department of Justice (DOJ) Secretary who issued a Department
Order creating a special panel of prosecutors to conduct preliminary investigation on the
death of media man. During the course of the investigation, the suspects pointed to Mario
Joel T Reyes, herein respondent, as the mastermind who ordered the killing of said media
man.

However, the special panel of prosecutors found no compelling evidence to establish

probable course for the filling of criminal charges against herein respondent. Before such
finding was formally appealed before the DOJ, herein petitioner Secretary De Lima, in
the interest of service and due process, issued another Department Order, creating a
second panel of prosecutors for the reception of evidence with was duly denied by the first
panel of prosecutors.

This time, the second panel of prosecutors found probable cause, thus filing criminal
charges against herein respondent before the RTC.

The respondent however, argues that the findings of the second panel of prosecutors as
void and must not enforced by the RTC since all parties had already been given the
opportunity to present their evidence before the First Panel so it was not necessary to
conduct a reinvestigation in the first place.

ISSUE
Whether the Petition for Certiorari, assailing the findings of the preliminary investigation,
has already been rendered moot by the filing of the information in court.

RULE
The filing of the information and the issuance by the trial court of the respondent's
warrant of arrest has already rendered the Petition moot.

A preliminary investigation is merely preparatory to a trial. It is not a trial on the merits.

An accused's right to a preliminary investigation is merely statutory; it is not a right
guaranteed by the Constitution. Hence, any alleged irregularity in an investigation's
conduct does not render the information void nor impair its validity.

Once the information is filed in court, the court acquires jurisdiction of the case and any
motion to dismiss the case or to determine the accused's guilt or innocence rests within
the sound discretion of the court.
3. G.R. No. 206147
MICHAEL C. GUY, Petitioner,
vs.
ATTY. GLENN C. GACOTT, Respondent

FACTS
Herein respondent Gacott ordered several units of transreceivers from Quantech Systems
Corporation (QSC). Due to major defects, Gacott personally returned the transreceivers
to QSC and requested that they be replaced. Despite several demands, both oral and
written, Gacott was never given a replacement or a refund. Thus, Gacott filed a complaint
for damages. Summons was served upon QSC and Medestomas.

The RTC rendered in favor of the plaintiff, ordering the defendants to jointly and severally
pay plaintiff.

During the execution of judgement, Gacott learned that QSC was not a corporation, but
was in fact a general partnership registered with the Securities and Exchange Commission
(SEC). In the articles of partnership, Guy was appointed as General Manager of QSC.
Upon learning that Guy had vehicles registered in his name, Gacott instructed the sheriff
to proceed with the attachment of one of the motor vehicles of Guy.

Guy filed his Motion to Lift Attachment Upon Personalty, arguing that he was not a
judgment debtor and, therefore, his vehicle could not be attached.

ISSUE
Whether or not petitioner may be held solidarily liable with the partnership for damages
arising from the breach of the contract.

RULE
No, although a partnership is based on delectus personae or mutual agency, whereby any
partner can generally represent the partnership in its business affairs, it is non sequitur
that a suit against the partnership is necessarily a suit impleading each and every partner.
It must be remembered that a partnership is a juridical entity that has a distinct and
separate personality from the persons composing it.

In relation to the rules of civil procedure, it is elementary that a judgment of a court is

conclusive and binding only upon the parties and their successors-in-interest after the
commencement of the action in court. A decision rendered on a complaint in a civil action
or proceeding does not bind or prejudice a person not impleaded therein, for no person
shall be adversely affected by the outcome of a civil action or proceeding in which he is
not a party. The principle that a person cannot be prejudiced by a ruling rendered in an
action or proceeding in which he has not been made a party conforms to the constitutional
guarantee of due process of law.
4. G.R. No. 198172
REGULUS DEVELOPMENT, INC., Petitioner,
vs.
ANTONIO DELA CRUZ, Respondent.

FACTS
The petitioner is the owner of an apartment wherein Antonio dela Cruz (respondent)
leased two units. The petitioner sent the respondent a letter to terminate the lease of the
two subject units. Due to the respondent’s refusal to vacate the units, the petitioner filed
a complaint for ejectment before the Metropolitan Trial Court (MTC).
The MTC resolved the case in the petitioner’s favor and ordered the respondent to vacate
the premises, and pay the rentals due until the respondent actually complies.
The respondent appealed to the Regional Trial Court (RTC). Pending appeal, the
respondent consigned the monthly rentals to the RTC due to the petitioner’s refusal to
receive the rentals.
The RTC affirmed the decision of the MTC in toto and denied the motion for
reconsideration filed by the respondent.
In a Petition for Review filed by the respondent, the CA reversed the lower courts’
decisions and dismissed the ejectment case.
The petitioner filed a motionnpraying for the withdrawal of the rentals consigned by the
respondent with the RTC, which was subsequently granted. The petitioner claimed that
the withdrawn deposits, supersedeas bond, and payments directly made by the
respondent to the petitioner, were insufficient to cover rentals due and prayed that the
RTC levy upon the respondent’s real property to satisfy the judgment credit.
Thereafter, the respondent filed with the CA a Petition for Certiorari25 with application
for issuance of a temporary restraining order. The petition sought to nullify and set aside
the orders of the RTC directing the levy of the respondent’s real property. The CA
dismissed the petition.
Pursuant to the order, a public auction for the respondent’s property where the petitioner
was declared highest bidder.
The respondent redeemed the property with the RTC Clerk of Court, paying the equivalent
of the petitioner’s bid price with legal interest. The petitioner filed a motion to release
funds for the release of the redemption price paid.
The respondent filed a manifestation and motion before the CA to withdraw the petition
for the reason that the redemption of the property and release of the price paid rendered
the petition moot and academic.
Thereafter, the petitioner received the CA decision which reversed and set aside the orders
of the RTC directing the levy of the respondent’s property. The CA held that while the
approval of the petitioner’s motion to withdraw the consigned rentals and the posted
supersedeas bond was within the RTC’s jurisdiction, the RTC had no jurisdiction to levy
on the respondent’s real property.

ISSUE
Whether the RTC had jurisdiction to levy on the respondent’s real property.

HELD
The levy of the respondent’s property was made pursuant to the RTC orders issued in the
exercise of its equity jurisdiction, independent of the ejectment case originally filed with
the MTC.

The RTC’s equity jurisdiction is separate and distinct from its appellate jurisdiction on
the ejectment case. The RTC could not have issued its orders in the exercise of its appellate
jurisdiction since there was nothing more to execute on the dismissed ejectment case. As
the RTC orders explained, the dismissal of the ejectment case effectively and completely
blotted out and cancelled the complaint. Hence, the RTC orders were clearly issued in the
exercise of the RTC’s equity jurisdiction, not on the basis of its appellate jurisdiction.
5. G.R. No. 199194
REPUBLIC OF THE PHILIPPINES, Petitioner,
vs.
JOSE B. SAREÑOGON, JR., Respondent.

FACTS
Herein respondent Jose B. Sareñogon, Jr. (Jose) filed a Petition before the Regional Trial
Court (RTC) for the declaration of presumptive death of his wife. The RTC held that Jose
had established by preponderance of evidence that he is entitled to the relief prayed for.
The Republic, through the Office of the Solicitor General (OSG), elevated the judgment of
the RTC to the CA via a Petition for Certiorari28 under Rule 65 of the Revised Rules of
Court.

The CA held that the Republic used the wrong recourse by instituting a petition for
certiorari under Rule 65 of the Revised Rules of Court. The CA essentially ruled that, "[a]
writ of certiorari may not be used to correct a lower court’s evaluation of the evidence and
factual findings. In other words, it is not a remedy for mere errors of judgment, which are
correctible by an appeal.

ISSUE

Whether or not Rule 65 of the Revised Rules of Court is the proper remedy to challenge
an RTC’s immediately final and executory Decision on a presumptive death.

HELD

Yes, We held that the RTC’s Decision on a Petition for declaration of presumptive death
pursuant to Article 41 of the Family Code is immediately final and executory. Thus, the
CA has no jurisdiction to entertain a notice of appeal pertaining to such judgment. Further
therein pointed out that the correct remedy to challenge the RTC Decision was to institute
a petition for certiorari under Rule 65, and not a petition for review under Rule 45.

By express provision of law, the judgment of the court in a summary proceeding shall be
immediately final and executory. As a matter of course, it follows that no appeal can be
had of the trial court’s judgment in a summary proceeding for the declaration of
presumptive death of an absent spouse under Article 41 of the Family Code. It goes
without saying, however, that an aggrieved party may file a petition for certiorari to
question abuse of discretion amounting to lack of jurisdiction. Such petition should be
filed in the Court of Appeals in accordance with the Doctrine of Hierarchy of Courts. To
be sure, even if the Court’s original jurisdiction to issue a writ of certiorari is concurrent
with the RTCs and the Court of Appeals in certain cases, such concurrence does not
sanction an unrestricted freedom of choice of court forum.
6. G.R. No. 183652 February 25, 2015
PEOPLE OF THE PHILIPPINES and AAA, Petitioner,
vs.
COURT OF APPEALS, 21st DIVISION, MINDANAO STATION, RAYMUND
CARAMPATANA, JOEFHEL OPORTO, and MOISES ALQUIZOLA, Respondents.

FACTS

Private respondents Carampatana, Oporto and Alquizola were charged and found guilty
by the RTC for raping private petitioner AAA. Aggrieved by the RTC Decision, private
respondents brought the case to the CA.

The CA found that the prosecution failed to prove private respondents’ guilt beyond
reasonable doubt, hence reversed the decision rendered by the RTC and acquitted private
respondents of the crime charged.

Private petitioner AAA, through her private counsel, filed a Petition for Certiorari9 under
Rule 65, questioning the CA Decision which reversed private respondents’ conviction and
ardently contending that the same was made with grave abuse of discretion amounting to
lack or excess of jurisdiction.

ISSUE
Whether or not Judgment of Acquittal is immediately final and executory and cannot be
appealed because of the Constitutional prohibition against Double Jeopardy.

HELD
As a general rule, the prosecution cannot appeal or bring error proceedings from a
judgment rendered in favor of the defendant in a criminal case. The reason is that a
judgment of acquittal is immediately final and executory, and the prosecution is barred
from appealing lest the constitutional prohibition against double jeopardy be violated.

Despite acquittal, however, either the offended party or the accused may appeal, but only
with respect to the civil aspect of the decision. Or, said judgment of acquittal may be
assailed through a petition for certiorari under Rule 65 of the Rules of Court showing that
the lower court, in acquitting the accused, committed not merely reversible errors of
judgment, but also exercised grave abuse of discretion amounting to lack or excess of
jurisdiction, or a denial of due process, thereby rendering the assailed judgment null and
void. If there is grave abuse of discretion, granting petitioner’s prayer is not tantamount
to putting private respondents in double jeopardy.
7. G.R. No. 188720
QUEZON CITY PTCA FEDERATION, INC., Petitioner,
vs.
DEPARTMENT OF EDUCATION, represented by SECRETARY JESLI A. LAPUS,
Respondent.

FACTS
The Department of Education, through Former Secretary Jesli A. Lapus, issued a
Department Order entitled Revised Guidelines Governing Parents-Teachers Associations
(PTAs) at the School Level.

Petitioner Quezon City PTCA Federation filed a Petition directly to the Supreme Court in
the belief that the above-quoted provisions undermine the independence of PTAs and
PTCAs, effectively amend the constitutions and by-laws of existing PTAs and PTCAs, and
violate its constitutional rights to organize and to due process, as well as other existing
laws.

The Department of Education contends that he issuance of the Department Order was a
valid exercise of the Department of Education’s rule-making powers, the assailed
provisions of the Department Order (i.e., Article II (2) and (3), Article IV (1)(e), and
Article X) undermine the organizational independence of parent-teacher associations and
further assails the filing of this Petition as being violative of the principle of hierarchy of
courts.

ISSUE

Whether or not the present Petition was filed in violation of the principle of hierarchy of
courts.

HELD

We sustain the position of the Department of Education. The present Petition was filed in
violation of the principle of hierarchy of courts. On this score alone, the Petition should
be dismissed.

It is true that petitions for certiorari and prohibition under Rule 65 of the 1997 Rules of
Civil Procedure fall under the original jurisdiction of this court. However, this is also true
of regional trial courts and the Court of Appeals.

"[T]his Court will not entertain a direct invocation of its jurisdiction unless the redress
desired cannot be obtained in the appropriate lower courts, and exceptional and
compelling circumstances justify the resort to the extraordinary remedy of a writ of
certiorari." Indeed, "concurrence [of jurisdiction] does not allow unrestricted freedom of
choice of the court forum. A direct invocation of the Supreme Court’s original jurisdiction
to issue this writ should be allowed only when there are special and important reasons,
clearly and specifically set out in the petition.
8. GR No. 215802, Oct 19, 2016
RIZALINA GEMINA, et al., Petitioners,
vs.
JUANITO EUGENIO, et al., Respondents.

FACTS
Spouses Candido Eugenio and Fernanda Geronimo (Spouses Eugenio) were the
registered owners of a parcel of land. Petitioners Rizalina Gemina, Rosario Acantilado
and Juanita Reyes are the heirs of Cristina and Severina; petitioner Efren Eugenio is the
heir of Catalino; petitioners Perfecto Eugenio, Romelia Eugenio, Amador Eugenio, Jr.,
Antonio Eugenio, Elvira Simeon, and Lerma Rebac are the heirs of Antero; and petitioner
Tomas Eugenio is the heir of Tomas.
Rizalina learned that the subject property was sold by a certain Francisco Eugenio
(Francisco) to respondent Spouses Laurel and Zenaida Mariano (Spouses Mariano.
The petitioners called the attention of Spouses Mariano regarding the subject property.
According to Spouses Mariano, they bought 4,000 square meters of the subject property,
brokered by Francisco, through two (2) deeds of absolute sale.
The matter not being settled, the petitioners filed a complaint for annulment of the
instruments before the RTC. They alleged that they were the legal heirs of the deceased
Spouses Eugenio, who were the registered owners of the subject property. They further
averred that the vendors sold the subject property without the consent of all the legal
heirs, thus, the contract of sale was null and void.

ISSUE
Whether the petitioners must institute a special proceeding to determine their status as
heirs before they could file an ordinary action for annulment of instrument.

HELD
Yes, The petitioners, however, have yet to substantiate their claim as the legal heirs of
Spouses Eugenio who are, thus, entitled to the subject property. Neither is there anything
in the records of this case which would show that a special proceeding had been instituted
to have themselves declared as heirs of Spouses Eugenio. Thus, there is a need to establish
their status as such heirs in the proper forum.

By way of exception, the need to institute a separate special proceeding for the
determination of heirship may be dispensed with if it appears from the records of the case
that the only property left by the decedent was the subject matter of the case and that the
parties had already presented evidence to establish their right as heirs of the decedent, or
when a special proceeding had been instituted but had been finally closed and terminated,
and hence, could not be re-opened.

Here, none of the foregoing exceptions, or any of similar nature, appears to exist. There
is a greater necessity for the institution of a special proceeding for the determination of
the lawful heirs of Spouses Eugenio.
9. GR No. 211539, Oct 17, 2016
THAMERLANE M. PEREZ, Petitioner,
vs.
DOMINADOR PRISCILLA RASACEÑA , Respondent.

FACTS
Petitioner filed a complaint for unlawful detainer before the MeTC against respondents
Dominador Rasacefia, Priscilla Navarro, and Adelfa Lim. He alleged that he is the
absolute owner of the property in controversy. He acquired the property from LNC
through a Deed of Conditional Sale and, subsequently, through a Deed of Absolute Sale.
The previous owner, LNC, tolerated respondents' occupancy of the subject property.
Petitioner, through his counsel demanded respondents to vacate the property, but the
latter refused to heed.
The parties failed to settle amicably. Hence, the complaint, praying that respondents be
ordered to vacate the premises and restore the possession of the property to the
petitioner; to pay a reasonable rent in the amount for the use and occupation of the same;
and, to pay moral damages, attorney's fees and costs.
However, respondents alleged that they leased the property from Agus Development
Corporation (Agus). They contended that: the court has no jurisdiction over the person of
the respondents; the case is barred by prior judgment or res judicata; there is no lessor-
lessee relationship between the parties; petitioner has no cause of action against
respondents; and the condition precedent for the filing of the complaint was not complied
with as there was no demand to vacate.
The MeTC ruled in favor of petitioner.
Thereafter, respondents elevated the case before the RTC. The RTC affirmed in toto the
Decision of the MeTC.
Aggrieved, respondents filed a petition for review before the CA. The CA reversed and set
aside the decision of the RTC. Petitioner failed to prove that his predecessor-in-interest
tolerated respondents' possession of the property. He did not offer any evidence attesting
that LNC tolerated the occupation. His complaint was silent as to the factual
circumstances surrounding the alleged tolerance, or averment of an overt act indicative
of LNC's permission.

ISSUE
Who has the better title to the material possession of the property?

HELD
We agree with the MeTC, as affirmed by the RTC, that petitioner has proven that he is
better entitled to the material possession of the property as against the unsubstantiated
claims of respondents.

To reiterate, the only question that the courts resolve in ejectment proceedings is: who is
entitled to the physical possession of the premises, that is, to the possession de facto and
not to the possession de jure. It does not even matter if a party's title to the property is
questionable. Where the issue of ownership is raised by any of the parties, the courts may
pass upon the same in order to determine who has the right to possess the property.

In the case at bar, petitioner anchors his claim of ownership and right to possess the
property on the strength of a notarized Deed of Conditional Sale and a notarized Deed of
Absolute Sale between him and LNC. Regarded as evidence of the facts therein expressed
in a clear, unequivocal manner, public documents enjoy a presumption of regularity
which may only be rebutted by evidence so clear, strong and convincing as to exclude all
controversy as to falsity.
10. GR No. 160864
PEOPLE OF THE PHILIPPINES, Petitioner,
vs.
EDUARDO M COJUANGCO, JR, Respondent.

x-----------------------------------------------------x
GR. No. 160897
PEOPLE OF THE PHILIPPINES, Petitioner,
vs.
EDUARDO M COJUANGCO, JR, Respondent.

FACTS
The Presidential Commission on Good Governance (PCGG) conducted a preliminary
investigation against herein respondent Eduardo M Cojuangco Jr, alleging that the latter
willfully and unlawfully acted as nominee and/ or dummy of the former President
Ferdiand E Marcos in acquiring shares of stock in the Bulletin Today Publishing Company
and Liwayway Publishing Inc., both private corporations, thereby inducing and/or
causing then President Marcos to directly or indirectly, participate in the management
and control of and/ or have pecuniary or financial interest in the said corporations.

However, after the filing of the proper charges against the respondent, the Sandiganbayan
later on issued a Resolution declaring null and void the preliminary investigation
conducted by the PCGG and Information filed pursuant thereto. The Sandiganbayan
found the investigation arbitrary and unjust, because the entity that had gathered the
evidence to support the Information filed against respondent – the PCGG – was also the
entity that had conducted the preliminary investigation of his case.

ISSUE
Whether or not the Sandiganbayan erred when it declared null and void the preliminary
investigation conducted by the PCGG and the Information filed pursuant to that
investigation.

HELD
It was noted that prior to the conduct of the preliminary investigation, the PCGG had
gathered evidence against respondent, issued a sequestration order against him, and filed
a civil case for recovery of ill-gotten wealth based on the same facts involved in the
criminal cases. Based on those circumstances, the Court found that the PCGG could not
have possibly acted with the "cold neutrality of an impartial judge" during the preliminary
investigation proceedings, since the latter had already formed conclusions on the matter.
11. G.R. No. 213847 August 18, 2015
JUAN PONCE ENRILE, Petitioner,
vs.
SANDIGANBAYAN (THIRD DIVISION), AND PEOPLE OF THE PHILIPPINES,
Respondents.

FACTS
Herein petitioner JUAN PONCE ENRILE was charged with plunder before the
Sandiganbayan for his alleged involvement in the diversion and misuse of appropriation
of government funds. When his warrant was issued, respondent Enrile voluntarily
surrendered and later on filed a motion to fix bail arguing that: He should be allowed to
post bail as a matter of right; That he is not a flight risk and his medical condition must
be seriously considered;

The Sandiganbayan however, denied his motion on the grounds that:

1. He is charged with a capital offense;
2. That it is premature for the Court to fix the amount of his bail because the
prosecution have not yet presented its evidences.

Sen. Enrile then filed a certiorari before the Supreme Court.

ISSUE
Whether or not the Sandiganbayan acted with grave abuse of discretion amounting to lack
or excess of jurisdiction for denying his motion to fix bail?

HELD
Yes, the Supreme Court held that Bail is a matter right and is safeguarded by the
constitution, its purpose is to ensure the personal appearance of the accused during trial
or whenever the court requires and at the same time recognizing the guarantee of due
process which is the presumption of his innocence until proven guilty.

The Supreme Court further explained that Bail for the provisional liberty of the accused,
regardless of the crime charged should be allowed independently of the merits charged,
provided his continued incarceration is injurious to his health and endanger his life.

Hence, the Sandiganbayan failed to observe that if Sen. Enrile be granted the right to bail
it will enable him to have his medical condition be properly addressed and attended,
which will then enable him to attend trial therefore achieving the true purpose of bail.
12. G.R. No. 220598

GLORIA MACAPAGAL ARROYO, Petitioner,

vs.
PEOPLE OF THE PHILIPPINES AND THE SANDIGANBAYAN, (First Division),
Respondents

FACTS
The Ombudsman charged in the Sandiganbayan herein petitioner former President
Gloria Macapagal-Arroyo and PCSO Budget and Accounts Manager Aguas for conspiracy
to commit plunder, as defined by, and penalized under Section 2 (b) of Republic Act
(R.A.) No. 7080, as amended by R.A. No. 7659.
Thereafter, accused GMA and Aguas separately filed their respective petitions for bail
which were denied by the Sandiganbayan on the ground that the evidence of guilt against
them was strong.
After the Prosecution rested its case, accused GMA and Aguas then separately filed their
demurrers to evidence asserting that the Prosecution did not establish a case for plunder
against them. The same were denied by the Sandiganbayan, holding that there was
sufficient evidence to show that they had conspired to commit plunder.
After the respective motions for reconsideration filed by GMA and Aguas were likewise
denied by the Sandiganbayan, they filed their respective petitions for certiorari.

ISSUE
Whether or not the special civil action for certiorari is proper to assail the denial of the
demurrers to evidence.

HELD
Certiorari is proper since the Sandiganbayan gravely abused its discretion in denying
GMA’s demurrer to evidence.

The special civil action for certiorari is generally not proper to assail such an interlocutory
order issued by the trial court because of the availability of another remedy in the ordinary
course of law. Moreover, Section 23, Rule 119 of the Rules of Court expressly provides,
“the order denying the motion for leave of court to file demurrer to evidence or the
demurrer itself shall not be reviewable by appeal or by certiorari before judgment.”

“In the exercise of our superintending control over other courts, we are to be guided by
all the circumstances of each particular case ‘as the ends of justice may require.’ So it is
that the writ will be granted where necessary to prevent a substantial wrong or to do
substantial”
13. GR No. 204419, Nov 07, 2016
PEOPLE OF THE PHILIPPINES, Petitioner,
vs.
HON. EDMAR P. CASTILLO, Respondent.

FACTS
Herein respondent MTC Judge, issued a search warrant against the premises of Rabino
for violation of RA 9165. A search was conducted wherein the PDEA and PNP found 1
sachet of shabu. Rabino was charged with violation of RA 9165.

Before arraignment, Rabino filed a Motion to Quash Search Warrant and for Suppression
of Illegally Acquired Evidence, citing lack of probable cause among other grounds. Judge
Castillo granted the motion to quash, holding that because the minimum penalty for
illegal possession of methamphetamine hydrochloride or shabu is imprisonment of 12
years and 1 day to 20 years, which penalty is way beyond imprisonment of 6 years, MTC
Gattaran did not have jurisdiction to entertain the application for and to issue the search
warrant. As such, the search warrant is null and void and all proceedings had in virtue
thereof are likewise null and void.

ISSUE
Whether or not respondent MTC Judge may issue search warrant involving offenses
outside his jurisdiction.

HELD
It must be noted that nothing in the above-quoted rule does it say that the court issuing a
search warrant must also have jurisdiction over the offense. A search warrant may be
issued by any court pursuant to Section 2, Rule 126 of the Rules of Court and the resultant
case may be filed in another court that has jurisdiction over the offense committed. What
controls here is that a search warrant is merely a process, generally issued by a court in
the exercise of its ancillary jurisdiction, and not a criminal action to be entertained by a
court pursuant to its original jurisdiction. Thus, in certain cases when no criminal action
has yet been filed, any court may issue a search warrant even though it has no jurisdiction
over the offense allegedly committed, provided that all the requirements for the issuance
of such warrant are present.
14. GR No. 223290
WOODROW B CAMASO, Petitioner,
vs.
TSM SHIPPING (PHILS), INC., UTKILEN, and/or JONES TULOD, Respondents

FACTS
Petitioner and Respondent are into a Labor Dispute pertaining to claims by the former
against the latter. The Labor Arbiter rule in favor of the petitioner, however when the case
was elevated to the NLRC, the decision of the Labor Arbiter was reversed and
consequently dismissed petitioner’s complaint for lack of merit.

Aggrieved, petitioner thereafter filed a petition for certiorari before the Court of Appeals,
however it was later on dismissed for non-payment of the required docketing fees as
required by law.

ISSUE
Whether or not the CA correctly dismissed Camaso' s petition for certiorari before it for
nonpayment of docket fees.

HELD
Verily, the failure to pay the required docket fees per se should not necessarily lead to the
dismissal of a case. It has long been settled that while the court acquires jurisdiction over
any case only upon the payment of the prescribed docket fees, its non-payment at the time
of filing of the initiatory pleading does not automatically cause its dismissal provided that:
(a) the fees are paid within a reasonable period; and (b) there was no intention on the part
of the claimant to defraud the government.

Here, it appears that when Camaso filed his certiorari petition through his counsel and
via mail, a Metrobank check dated July 6, 2015 under the account name of Pedro L.
Linsangan was attached thereto to serve as payment of docket fees. Although this was not
an authorized mode of payment under Section 6, Rule VIII of the 2009 IRCA, the
attachment of such personal check shows that Camaso exerted earnest efforts to pay the
required docket fees. Clearly, this exhibits good faith and evinces his intention not to
defraud the government.

In light of the foregoing circumstances, the Court deems it appropriate to relax the
technical rules of procedure in the interest of substantial justice and, hence, remands the
instant case to the CA for the resolution of its substantial merits.