Case Digest (G.R. No. L-19550) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Harry S. Stonehill, Robert P. Brooks, John J. Brooks and Karl Beck v. Hon. Jose W. Diokno et al. (126 Phil. 738, June 19, 1967), petitioners challenged forty-two search warrants issued in early March 1962 by various Manila and Quezon City courts upon applications filed by the Secretary of Justice, the Acting Director of the NBI, and Special Prosecutors. The warrants, directed at petitioners and at corporations of which they were officers, authorized peace officers to search specified offices, warehouses, and residences and 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” allegedly related to violations of Central Bank Laws, Tariff and Customs Laws, the Internal Revenue Code, and the Revised Penal Code. On March 20, 1962, petitioners filed an original action for certiorari, prohibition, mandamus and injunction wit Case Digest (G.R. No. L-19550) Expanded Legal Reasoning Model
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)