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PEOPLE OF THE PHILIPPINES v. DEBORAH WOOLCOCK et.

al
244 SCRA 235 | May 22, 1995
Regalado, J.

Doctrines:
1. The validity of a search warrant can only be sought in the court that issued it, not in the
sala of another judge of concurrent jurisdiction.
2. The fact that a police mission proceeded with commendable precision and resulted in
total success shows that the police acted upon verified personal knowledge and not on
unreliable hearsay information.

FACTS
An information was filed against accused-appellants for violation of Sec. 11 of the
Dangerous Drugs Act of 1972 before the RTC. It is alleged in the information that the accused-
appellants, in conspiracy with each other, delivered, gave away and distributed heroin in Pasay
City and other parts of Metro Manila. It is said that police authorities received an intelligence
information that accused-appellants Woolcock and Daughtry were due to meet a black foreign
national for the delivery of prohibited drugs. The intel report also disclosed the hotel wherein the
two were staying. Acting on the basis of said report, police authorities formed three separate
teams to conduct surveillance on Woolcock, Daughtry and the black man who was later
identified as Williams and found that Williams indeed went to the hotel rooms of Woolcock and
Daughtry carrying a gray travelling bag. This was followed by another intelligence report which
stated that Woolcock was scheduled to leave the country which prompted the authorities to
station themselves at NAIA.
Upon the arrival of Woolcock at NAIA, she submitted her luggage for inspection. It was
initially cleared but upon re-inspection, a black bag revealed a false bottom which contains
substance positively identified as heroin. Instantly, Woolcock was arrested. Following such
development, police authorities caused the filing for application of search warrants directed at
other accused-appellants. When the same was served, hereoin was found in the things of
Daughtry and Asare. The trial court then issued the assailed decision and convicted them of the
crime charged.
All accused-appellants deny the charges against them and presented their own alibis.
They all allege that they did not know each other prior to their arrest. They also fault the trial
court for not resolving their motion to quash the search warrants and in not holding that appellant
Woolcock was subjected to an illegal arrest since the ownership of the black bag was not
established.

ISSUES AND HOLDING

1. W/N the trial court erred in not quashing the search warrants? NO.
To begin, appellants fault the Pasay RTC for not resolving their motion to quash the
search warrant issued by Caloocan RTC. They allege that they have initially filed said motion to
quash to the latter court but the same was denied. But when a criminal case was filed against
them in Pasay RTC, they renewed the attack on the said search warrants. However, it must be
noted that the Pasay RTC and Caloocan RTC are of equal and concurrent jurisdiction. They are

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equal in rank. As correctly argued by the Solicitor General, the remedy for questioning the
validity of a search warrant can only be sought in the court that issued it, not in the sala of
another judge of concurrent jurisdiction.

2. W/N the search warrants is void for allegedly being issued without probable cause? NO.
Another contention of the accused-appellants is that the search warrants were issued
without probable cause. They contend that the police officers have no personal knowledge that a
crime was being committed hence the judge issued the same based on hearsay information.
However, it is undisputed that the police authorities received an intelligence information from a
reliable source and also formed three teams to conduct surveillance on their activities. And even
assuming arguendo that the search warrants were void, a warrantless search is still justified in
light of similar considerations in People v. Malmstedt.

3. W/N appellant Woolcock was subjected to an illegal arrest? NO.


Meanwhile, appellant Woolcock contents that her arrest was illegal due to the failure of the
prosecution to prove the ownership of the black bag containing heroin. However, the
surveillance team saw the bag being delivered to her, she was also prominently seen outside the
hotel carrying the same bag and she retained possession of which until it was submitted for the
standard customs operational inspection justifies the warrantless arrest.
Lastly, her reliance to People v Amminudin is misplaced because unlike in the present case
wherein the authorities conducted surveillance on her and made no move until it was verified
that she carries with her prohibited drugs, the police in Amminudin had 2 days to secure a
warrant and they also had no probable cause when they arrested Amminudin but merely relied on
the pointing finger of their informant.

WHEREFORE, the appealed judgment of the Regional Trial Court, Branch 113, Pasay City in
Criminal Case No. 92-1912 is hereby AFFIRMED in toto, with costs against accused appellants.

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