FACTS:

Petitioner Senator Leila De Lima sought relief through a Petition for Certiorari and Prohibition, challenging orders and a warrant issued by Judge Juanita Guerrero of the RTC Muntinlupa, Branch 204, in Criminal Case No. 17-165. The Senate and House inquiries into the proliferation of drugs at the New Bilibid Prison led to multiple complaints filed against De Lima with the DOJ. The DOJ consolidated these complaints and conducted a preliminary investigation, during which De Lima, through counsel, questioned jurisdiction and sought endorsements to the Office of the Ombudsman.

Following the preliminary investigation, the DOJ Panel recommended filing Informations against De Lima. The RTC Muntinlupa issued a warrant for her arrest, which she challenged via a Motion to Quash. The RTC, however, found probable cause for her arrest. De Lima's petition argued the RTC's lack of jurisdiction and cited procedural missteps. The warrant was served, and De Lima was detained. She urged the Court for writs that would nullify the arrest order and discontinue further proceedings until her Motion to Quash was resolved.

Testimonies from various sources, including convicted inmates and NBI officials, implicated De Lima in receiving funds from drug trade proceeds to support her senatorial campaign. The evidence cited confirmed delivery of money to De Lima’s residence by co-accused Rafael Ragos and others under the premise that these were drug trade profits solicited from inmates. The petitioner suggested the charges should fall under the jurisdiction of the Sandiganbayan given her official capacity. The state, supported by the Solicitor General’s validation, responded by asserting RTC jurisdiction over violations of the Comprehensive Dangerous Drugs Act (RA 9165).

ISSUES:

Procedural Issues

1. Whether the petitioner is excused from compliance with the doctrine on hierarchy of courts considering that the petition should first be filed with the Court of Appeals.

2. Whether the pendency of the Motion to Quash the Information before the trial court renders the instant petition premature.

3. Whether the petitioner, in filing the present petition, violated the rule against forum shopping given the pendency of the Motion to Quash the Information before the Regional Trial Court of Muntinlupa City and the Petition for Certiorari filed before the Court of Appeals.

Substantive Issues

4. Whether the Regional Trial Court or the Sandiganbayan has jurisdiction over the violation of Republic Act No. 9165 averred in the Information.

5. Whether the respondent judge gravely abused her discretion in finding probable cause to issue the Warrant of Arrest against the petitioner.

6. Whether the petitioner is entitled to a Temporary Restraining Order and/or Status Quo Ante Order until the petition is resolved or until the trial court rules on the Motion to Quash.

RULING:

Procedural Issues

1. Doctrine on Hierarchy of Courts The Supreme Court ruled that the petitioner violated the doctrine on the hierarchy of courts. The case did not present sufficient justification to directly resort to the Supreme Court without first seeking recourse in the Court of Appeals.

2. Pendency of Motion to Quash The Supreme Court held that the petition was premature as the Regional Trial Court had yet to rule on the Motion to Quash. Thus, the proper course of action was to allow the trial court to decide on the motion first.

3. Forum Shopping The petitioner violated the rule against forum shopping. Since the same arguments and reliefs were essentially being sought in both the Motion to Quash and the petition, the concurrent actions constituted forum shopping.

Substantive Issues

4. Jurisdiction The Supreme Court ruled that the Regional Trial Court, not the Sandiganbayan, has jurisdiction over violations of Republic Act No. 9165. The law specifically grants the RTC exclusive authority to hear drug-related cases.

5. Probable Cause for Warrant of Arrest The Court found no grave abuse of discretion by the respondent judge in issuing the warrant of arrest against the petitioner. The judge properly evaluated the evidence presented during the preliminary investigation.

6. Temporary Restraining Order/Status Quo Ante Order The Supreme Court did not find merit in granting a Temporary Restraining Order or Status Quo Ante Order pending the resolution of the petition or the trial court’s decision on the Motion to Quash.

PRINCIPLES:

• Hierarchy of Courts Direct resort to a higher court is not justified when relief can be obtained in the lower courts, unless exceptional circumstances exist.

• Premature Petition A petition for certiorari or other remedies should not be filed before the trial court has had the opportunity to rule on pending motions or issues.

• Forum Shopping Multiple judicial remedies should not be sought simultaneously in different fora; doing so constitutes malpractice and may warrant dismissal of the actions filed.

• Jurisdiction The Regional Trial Court has exclusive jurisdiction over violations of Republic Act No. 9165. Exceptions in the jurisdiction of courts must be explicitly stated in the governing special laws.

• Determination of Probable Cause The issuance of a warrant of arrest requires the judge to personally evaluate the evidence. A motion to quash does not automatically stay the determination and issuance of such warrants.

• Admissibility of Evidence in Preliminary Investigation Hearsay evidence can support a finding of probable cause during preliminary investigation due to its preliminary and non-conclusive nature.