FACTS:

An application for a search warrant was filed with the RTC of Kalookan City by 1st Lt. Salboro of the CAPCOM Northern Sector. The search warrant was sought in connection with an alleged violation of P.D. 1866. A search warrant was issued and firearms, explosive materials, and subversive documents were seized during the search. The petitioners, who were EILER instructors, filed motions to quash the search warrant and suppress the evidence obtained, arguing that the court did not have jurisdiction to issue the search warrant for an offense committed outside its territorial jurisdiction. The Quezon City court denied the motions. The petitioners filed a petition for certiorari which was denied by the Court of Appeals. The petitioners now seek reversal of the decision through the present recourse.

This case revolves around the issuance of a search warrant in relation to the venue of a criminal action. The petitioners argue that a search warrant can only be issued by a court with jurisdiction over the place where the criminal case will eventually be filed. The respondents, on the other hand, contend that the issuance of a search warrant is a separate and distinct judicial process from the filing of a criminal action. They argue that a search warrant should be issued based on the jurisdiction of the court where the warrant is sought, regardless of where the criminal case will be filed. The parties' arguments center on the interpretation of the rules regarding the issuance of search warrants and the venue of criminal actions. The court notes that a search warrant is considered as a judicial process, and it is not necessary to determine the eventual venue of the criminal case at the time of seeking the warrant. The court emphasizes that the rules do not require such jurisdictional strictures and that imposing such conditions would be tantamount to judicial legislation.

The petitioners argue that only the branch of an RTC that has jurisdiction over the place to be searched can grant an application for and issue a warrant to search that place. However, the court rejects this proposition, stating that the circulars were not intended to be of general application to all instances involving search warrants and all courts. The court further states that adopting this rule would create a bifurcated procedure which could be legally and constitutionally objectionable. The court also dismisses the argument that Administrative Order No. 3 of the Supreme Court defines the limits of territorial jurisdiction of RTCs as it does not determine the subject matter jurisdiction of the courts, but rather the exercise of jurisdiction by the courts.

ISSUES:

1. Whether Circular No. 13 and Circular No. 19 confer jurisdiction on the courts to issue search warrants.

2. Whether Administrative Order No. 3 defines the territorial jurisdiction of the courts.

3. Whether the grant of power to certain courts to issue search warrants excludes other courts from exercising the same power.

4. Whether a court whose territorial jurisdiction does not embrace the place to be searched can issue a search warrant for that place.

5. Whether a branch of a regional trial court has the authority to issue a warrant for the search of a place outside its territorial jurisdiction.

6. Whether a search warrant issued by a court outside the territorial jurisdiction where the place to be searched is located violates the constitutional prohibition against illegal searches and seizures.

7. Whether the enforcement of a search warrant issued by a court outside the territorial jurisdiction where the place to be searched is located creates a possibility of forum shopping.

8. Whether there should be primary jurisdiction of the court wherein the criminal case is pending to issue search warrants necessitated by and for purposes of said case.

9. Whether a motion to quash a search warrant and a motion to suppress evidence are alternative and not cumulative remedies.

10. Whether objections not available, existent, or known during the proceedings for the quashal of the warrant may be raised in the hearing of the motion to suppress.

11. Whether the court which issued the search warrant is required to transmit all personal property seized under the warrant to the court where the criminal case is pending.

12. Whether the guidelines provided apply in cases where the same criminal offense is charged in different informations or complaints filed in two or more courts with concurrent original jurisdiction over the criminal action.

RULING:

1. Circular No. 13 and Circular No. 19 were not intended to be of general application to all instances involving search warrants and in all courts. These circulars were issued only to meet a particular exigency and are limited to violations of specific laws. The court rejects the proposition that these circulars confer jurisdiction on the courts to issue search warrants.

2. Administrative Order No. 3 is an administrative order that defines the limits of the administrative area within which a branch of the court may exercise its authority. It does not per se confer jurisdiction on the courts.

3. The grant of power to certain courts to issue search warrants does not exclude other courts from exercising the same power. The provision in Circular No. 19 that directs certain executive judges to personally act on applications for search warrants within their territorial jurisdictions is in the nature of an allocation of assignments among them and does not mandate the exclusion of all other courts.

4. A court whose territorial jurisdiction does not embrace the place to be searched can issue a search warrant if obtaining such warrant is necessitated by compelling considerations of urgency, subject, time, and place. A search warrant duly issued by a court with jurisdiction over a pending criminal case or by an executive judge or their lawful substitute under Circular No. 19 is valid and enforceable even if it is implemented outside the court's territorial jurisdiction.

5. Yes, a branch of a regional trial court has the authority to issue a warrant for the search of a place outside its territorial jurisdiction. No law or rule imposes limitations on search warrants or warrants of arrest in terms of territorial jurisdiction. The enforcement of search warrants and other processes issued by regional trial courts is not restricted to their judicial regions but can be served anywhere in the Philippines.

6. The enforcement of a search warrant issued by a court outside the territorial jurisdiction where the place to be searched is located does not violate the constitutional prohibition against illegal searches and seizures.

7. The possibility of law enforcement authorities resorting to forum shopping by filing an application for a search warrant with a "friendly" court is not a valid concern as there are specific safeguards outlined in Rule 126 of the 1985 Rules on Criminal Procedure that need to be observed regardless of which court issues the search warrant.

8. The court wherein the criminal case is pending shall have primary jurisdiction to issue search warrants necessary for said case. However, an application for a search warrant may be filed with another court under extreme and compelling circumstances, subject to the satisfaction of the latter court and its discretion in giving due course to the application.

9. A motion to quash a search warrant and a motion to suppress evidence are alternative and not cumulative remedies. A motion to quash shall be governed by the omnibus motion rule, and objections not available, existent, or known during the proceedings for the quashal of the warrant may be raised in the hearing of the motion to suppress.

10. The court which issued the search warrant is required to transmit all personal property seized under the warrant to the court where the criminal case is pending, with the necessary safeguards and documentation therefor.

11. The guidelines provided also apply in cases where the same criminal offense is charged in different informations or complaints filed in two or more courts with concurrent original jurisdiction over the criminal action.

PRINCIPLES:

• Jurisdiction is conferred by substantive law and not by procedural law or administrative orders.

• Administrative orders and circulars are issued to provide guidelines in the exercise of jurisdiction conferred by substantive law.

• The grant of power to certain courts to issue search warrants does not exclude other courts from exercising the same power.

• A search warrant can be issued by a court whose territorial jurisdiction does not embrace the place to be searched if there are compelling considerations of urgency, subject, time, and place.

• A search warrant duly issued by a court with jurisdiction over a pending criminal case or by an executive judge or their lawful substitute is valid and enforceable even if it is implemented outside the court's territorial jurisdiction.

• No law or rule imposes territorial limitations on search warrants or warrants of arrest unless expressly stated.

• The enforcement of search warrants and other processes issued by regional trial courts is not restricted to their judicial regions but can be served anywhere in the Philippines, unless specifically stated otherwise.

• The enforcement of a search warrant issued by a court outside the territorial jurisdiction where the place to be searched is located does not violate the constitutional prohibition against illegal searches and seizures.

• The possibility of law enforcement authorities resorting to forum shopping by filing an application for a search warrant with a "friendly" court is not a valid concern as there are specific safeguards outlined in Rule 126 of the 1985 Rules on Criminal Procedure that need to be observed regardless of which court issues the search warrant.

• The court wherein the criminal case is pending shall have primary jurisdiction to issue search warrants necessary for said case, but under extreme and compelling circumstances, an application for a search warrant may be filed with another court, subject to the satisfaction of the latter court and its discretion in giving due course to the application.

• A motion to quash a search warrant and a motion to suppress evidence are alternative and not cumulative remedies.

• A motion to quash shall be governed by the omnibus motion rule.

• Objections not available, existent, or known during the proceedings for the quashal of the warrant may be raised in the hearing of the motion to suppress.

• The court which issued the search warrant is required to transmit all personal property seized under the warrant to the court where the criminal case is pending.

• The guidelines provided apply in cases where the same criminal offense is charged in different informations or complaints filed in two or more courts with concurrent original jurisdiction over the criminal action.