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Malaloan v. CA May 6, 1994 Facts

This case discusses the validity of a search warrant issued by a Regional Trial Court in Kalookan City for firearms allegedly located in Quezon City. The petitioners argued the warrant was invalid because it was issued by a court in a different jurisdiction. However, the Court held that under the Judiciary Reorganization Act, search warrants are considered processes rather than criminal actions. The Interim Rules state that processes can be enforced anywhere in the Philippines, regardless of what court issued them. Therefore, the search warrant was deemed valid even though it was carried out outside the jurisdiction of the court that approved it.

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69 views1 page

Malaloan v. CA May 6, 1994 Facts

This case discusses the validity of a search warrant issued by a Regional Trial Court in Kalookan City for firearms allegedly located in Quezon City. The petitioners argued the warrant was invalid because it was issued by a court in a different jurisdiction. However, the Court held that under the Judiciary Reorganization Act, search warrants are considered processes rather than criminal actions. The Interim Rules state that processes can be enforced anywhere in the Philippines, regardless of what court issued them. Therefore, the search warrant was deemed valid even though it was carried out outside the jurisdiction of the court that approved it.

Uploaded by

Adel Bermejo
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Malaloan v.

CA
May 6, 1994

Facts:

Malaloan et. al. invoke the jurisdictional rules in the institution of criminal actions to invalidate
the search warrant issued by the Regional Trial Court of Kalookan City because it is directed
toward the seizure of firearms and ammunition allegedly cached illegally in Quezon City. This
theory is sought to be buttressed by the fact that the criminal case against petitioners for
violation of Presidential Decree No. 1866 was subsequently filed in the latter court. 

The application for the search warrant, it is claimed, was accordingly filed in a court of improper
venue and since venue in criminal actions involves the territorial jurisdiction of the court, such
warrant is void for having been issued by a court without jurisdiction to do so.

Legal Issue: Is the search warrant valid only within the territorial jurisdiction of the court who
issued the same?

Held:

Under the Judiciary Reorganization Act, the enforcement of such writs and processes no longer
needs the approval of the regional trial court. On the other hand, while, formerly, writs and
processes of the then courts of first instance were enforceable throughout the Philippines,
23under the Interim or Transitional Rules and Guidelines, certain specified writs issued by a
regional trial court are now enforceable only within its judicial region. In the interest of clarity and
contrast, it is necessary that said provision be set out in full:

3. Writs and processes.

(a) Writs of certiorari, prohibition mandamus, quo warranto, habeas corpus and injunction
issued by a regional trial court may be enforced in any part of the region.

(b) All other processes, whether issued by a regional trial court or a metropolitan trial court,
municipal trial court or municipal circuit trial court may be served anywhere in the Philippines,
and, in the last three cases, without a certification by the judge of the regional trial court.

We feel that the foregoing provision is too clear to be further belabored or enmeshed in
unwarranted polemics. The rule enumerates the writs and processes which, even if issued by a
regional trial court, are enforceable only within its judicial region. In contrast, it unqualifiedly
provides that all other writs and processes, regardless of which court issued the same, shall be
enforceable anywhere in the Philippines. As earlier demonstrated, a search warrant is but a
judicial process, not a criminal action. No legal provision, statutory or reglementary, expressly or
impliedly provides a jurisdictional or territorial limit on its area of enforceability. On the contrary,
the above-quoted provision of the interim Rules expressly authorizes its enforcement anywhere
in the country, since it is not among the processes specified in paragraph (a) and there is no
distinction or exception made regarding the processes contemplated in paragraph (b).

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