Title
Moncado vs. El Tribunal del Pueblo
Case
G.R. No. L-824
Decision Date
Jan 14, 1948
Moncado's documents seized without warrant deemed admissible despite illegal search; constitutional rights violated but evidence upheld as relevant.

Case Digest (G.R. No. L-824)

Facts:

  • Arrest and Seizure
    • On April 4, 1945 at about 6 PM, Moncado was arrested without warrant by members of the Counter Intelligence Corps (CIC) of the U.S. Army at his residence at 199A San Rafael St., Manila, and detained at Muntinglupa Prison, Rizal.
    • About one week later, CIC officers under Lt. Olves summoned Moncado’s wife, then residing at 3 Rosario Dr., Quezon City, to witness a warrantless search of the San Rafael house; she joined under protest and observed personal and official papers scattered on the floor, whereupon Lt. Olves declared he was seizing documents to prove her husband’s guilt.
  • Motions for Return of Documents
    • On June 27, 1946, Moncado filed a motion in the People’s Court for the return of the seized documents, arguing they were obtained without a search warrant; the court denied the motion on July 9, 1946, applying the military-occupation doctrine of Alvero v. Dizon (76 Phil. 637).
    • On August 10, 1946, Moncado petitioned the Supreme Court for certiorari to (a) annul the July 9 order, (b) compel the return of the documents, and (c) enjoin the Special Prosecutor from using them in Moncado’s treason trial, asserting violation of constitutional guarantees and lack of an adequate ordinary remedy.

Issues:

  • Whether the Alvero v. Dizon doctrine, which applied during U.S. military occupation, governs the seizure of documents made after restoration of the Commonwealth on February 27, 1945.
  • Whether documents seized without a judicially issued warrant are inadmissible and must be returned.
  • Whether admitting evidence obtained in violation of the constitutional right against unreasonable searches and seizures infringes due process and other guaranteed rights.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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