Case Digest (G.R. No. L-69803) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the case of Cynthia D. Nolasco, Mila Aguilar-Roque and Willie C. Tolentino v. Hon. Ernani Cruz Pano, et al. (G.R. No. 69803, 231 Phil. 458, En Banc, January 30, 1987), petitioners challenged the validity of Search Warrant No. 80-84, issued on August 6, 1984 by Executive Judge Pano of the Regional Trial Court of Quezon City in a subversive documents case. Acting on this warrant, military and police officers conducted searches of petitioners’ homes—including the dwelling of petitioner Mila Aguilar-Roque—and seized various documents and personal effects (“personalties”). Petitioners moved to annul the warrant in the lower courts as a general warrant lacking particularity and to declare illegal the warrantless search incident to an allegedly void arrest of Aguilar-Roque. The trial court issued a Temporary Restraining Order enjoining the use of the seized items as evidence. On October 8, 1985, this Court, by majority decision, annulled the warrant and made the TRO permanent but pe... Case Digest (G.R. No. L-69803) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioners
- Cynthia D. Nolasco
- Mila Aguilar-Roque
- Willie C. Tolentino
- Respondents
- Hon. Ernani Cruz Pano, Executive Judge, RTC, Quezon City
- Hon. Antonio P. Santos, Presiding Judge, MTC, Quezon City
- Hon. Sergio F. Apostol, City Fiscal, Quezon City
- Hon. Juan Ponce Enrile, Lt. Gen. Fidel Ramos, Col. Jesus Altuna
- Procedural History
- On August 6, 1984, Search Warrant No. 80-84 was issued by Judge Pano for “subversive documents,” leading to the seizure of books, papers and personal effects from the petitioners’ premises.
- On October 8, 1985, this Court’s Decision:
- Annulled and set aside Search Warrant No. 80-84 as void.
- Made permanent the Temporary Restraining Order enjoining respondents from introducing the seized evidence in the Subversive Documents Case.
- Permitted the Constabulary Security Group to retain the seized items for possible use in Criminal Case No. SMC-1-1 before Special Military Commission No. 1, subject to objections on relevance.
- Public respondents filed a Motion for Partial Reconsideration arguing the warrant’s validity and the special nature of rebellion offenses that complicates particularization of documents.
- Petitioners filed a Motion for Partial Reconsideration contending that the warrantless search of petitioner Aguilar-Roque’s home could not be justified as incident to her arrest, which they asserted was unlawful.
- On April 10, 1986, this Court required parties to file supplemental pleadings in light of supervening events (new administration).
- In their compliance:
- Petitioners maintained both the arrest and the search were illegal and sought return of all seized items.
- The Solicitor General, on behalf of public respondents, withdrew objections to declaring the search illegal and returning the items but would not concede the illegality of the arrests.
- On January 30, 1987, this Court promulgated the challenged Resolution granting petitioners’ motion in part and ordering the return of seized personalties.
Issues:
- Whether Search Warrant No. 80-84 complied with constitutional requirements against unreasonable searches and seizures.
- Whether the warrantless search of petitioner Aguilar-Roque’s dwelling was valid as an incident to her arrest.
- Whether the articles seized under the void warrant are admissible or must be returned to petitioners.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)