To quash or not to quash . . . the state of Philippine copyright case law

The recent decision by the Philippine Supreme Court in case of Sony Music Entertainment (Phils.), Inc. and IFPI (Southeast Asia), Ltd., vs. Solid Laguna Corporation G.R. No. 156804 in 2005 dealt another blow to efforts to curb copyright violations in the country.
In affirming the quashal of the search warrants used to raid a factory suspected of manufacturing pirated CDs/DVDs, the Supreme Court stated that:

“To us it is not enough that the applicant and his witnesses testify that they saw stacks of several alleged infringing, pirated and unauthorized discs in the subject facility. The more decisive consideration determinative of whether or not a probable cause obtains to justify the issuance of a search warrant is that they had personal knowledge that the discs were actually infringing, pirated or unauthorized copies. … It cannot be overemphasised that not one of them testified seeing the pirate discs being manufactured at SLC’s premises”

In requiring the witnesses in such instances to have actually seen pirated copies of copyrighted material being made is such a heavy evidentiary burden to impose upon the complainant, considering that obtaining a search warrant is merely an ancillary proceeding to the prosecution in court of copyright violators.
Also, considering the patent illegality of the operation, manufacturers of pirated OMDs (optical media discs) probably won’t leave their activities open to just about anyone to see right.
The Supreme Court seems to have forgotten that one does not need to show proof beyond a reasonable doubt in determining probable cause.
The sad thing is this isn’t the only instance that showed a lack of understanding of the nuances of copyright law enforcement in the country consider the case of 20th Century Fox vs Court of Appeals 164 SCRA 655 (1988), wherein the court required the presentation of the master tapes of the films alleged to have been pirated in order to justify the issuance of search warrants.
Will a copyright violator simply turn over the master tapes to anyone?! The court could have evaluated other types of evidence in determining the existence of probable cause.
No wonder, despite the existence of copyright laws in the country for over half a century, we still have a dearth of copyright case law or doctrines, as the main cases never prosper considering the case concerning the quashal of the search warrants that facilitated the acquisition of the prosecution’s damning evidence usually go against the complainants.