Title
Stonehill vs. Diokno
Case
G.R. No. L-19550
Decision Date
Jun 19, 1967
Search warrants invalid for lack of specificity; corporate officers lack standing to challenge corporate document seizures; evidence from residences inadmissible.

Case Digest (G.R. No. L-19550)
Expanded Legal Reasoning Model

Facts:

  • Search Warrants Applied and Issued
    • Between March 3 and March 9, 1962, Secretary of Justice Diokno, Acting NBI Director Lukban and several special prosecutors applied for and obtained 42 search warrants from various Municipal and CFI judges.
    • The warrants, addressed to any peace officer, authorized searches of petitioners Harry S. Stonehill, Robert P. Brooks, John J. Brooks, Karl Beck and their corporate offices, warehouses and residences to seize “books of accounts, financial records, vouchers, correspondence, receipts, ledgers, journals, portfolios, credit journals, typewriters, and other documents and/or papers showing all business transactions including disbursement receipts, balance sheets and profit and loss statements and Bobbins” under alleged violations of Central Bank, Tariff and Customs, Internal Revenue and Penal Code provisions.
  • Seizures and Procedural History
    • Physical seizures fell into two groups: (a) corporate premises (29 offices and warehouses of petitioners’ corporations) and (b) private residences of the four petitioners (three locations).
    • On March 20, 1962, petitioners filed an original action in the Supreme Court for certiorari, prohibition, mandamus and injunction, seeking to quash all warrants and restrain use of seized items in deportation proceedings. A preliminary injunction was granted on March 22, 1962; on June 29, 1962 it was dissolved as to corporate seizures but maintained for residential seizures.

Issues:

  • Standing
    • Do petitioners, as corporate officers, have cause of action to challenge seizures made at their corporations’ premises?
    • Do petitioners have standing to challenge seizures made at their private residences?
  • Validity of Warrants and Searches
    • Were the 42 warrants constitutionally valid in terms of probable cause, particularity of offense and description of items?
    • Were the searches and seizures under those warrants lawful?
  • Admissibility of Seized Evidence
    • If warrants/searches are invalid, may the seized documents and papers nevertheless be used in evidence against petitioners?
    • Should the exclusionary rule of Moncado v. People be maintained or abandoned?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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