Case Summary (G.R. No. L-19550)
Corporate‐Office Seizure: No Personal Cause of Action
The Court held that officers cannot challenge warrants issued against separate juridical personalities. Corporate entities alone may contest seizures of their property. Petitioners lacked standing to suppress corporate‐office seizures; rights infringed belonged to corporations, not individual officers. Their objection to use of corporate records in evidence was held invalid.
Residential Seizures: Challengeable Warrants
As to items seized at petitioners’ residences (three locations), the injunction remained in force. Two questions arose: (1) validity of the warrants and searches, and (2) admissibility of evidence if warrants were invalid.
Constitutional Requirements for Search Warrants
Under the 1935 Constitution, warrants must issue only upon probable cause determined by a judge after sworn examination of complainant and witnesses, and must particularly describe the place and items to be seized. The contested warrants alleged broad “violations” of multiple laws without specifying acts or particular offenses, and authorized seizure of virtually all business records.
Invalidity of Warrants as General Warrants
The applications described offenses abstractly (“violation of Central Bank Laws, Tariff and Customs Laws, Internal Revenue Code and Revised Penal Code”) and prescribed a sweeping list of documents covering all business transactions. This stripped the judge’s finding of probable cause of any factual basis and created impermissible general warrants, contrary to constitutional strictures and subsequent amendments to Rule 122.
Adoption of the Exclusionary Rule
Rejecting Moncado v. People’s Court (80 Phil. 1), the Court embraced the exclusionary rule as the only effective safeguard of constitutional rights. Citing U.S. precedent (Weeks, Wolf, Mapp), it held that evidence obtained through unconstitutional searches must be excluded to deter lawless intrusions and preserve the integrity of the Bill of Rights.
Final Disposition
• Warrants for residential searches declared null and void; searches and seizures thereunder illegal.
• Writ of preliminary injunction made permanent as to items seized from petitioners’ residences.
• Petitions and wr
Case Syllabus (G.R. No. L-19550)
Facts of the Case
- Respondent-Prosecutors applied for and obtained 42 search warrants (March 3–9, 1962) against petitioners and seventeen corporations of which they were officers.
- Warrants authorized searches of persons, corporate offices, warehouses and private residences, and seizure of “books of accounts, financial records, vouchers, correspondence, receipts, ledgers, journals, portfolios, credit journals, typewriters, and other documents and/or papers showing all business transactions … and Bobbins (cigarette wrappers).”
- Seized property described as “subject of the offense; stolen or embezzled and proceeds or fruits of the offense;” offense alleged as “violation of Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and the Revised Penal Code.”
Procedural History
- March 20, 1962: Petitioners filed original action for certiorari, prohibition, mandamus and injunction before the Supreme Court.
- Prayer: Quash search warrants, declare them null and void, require respondents to return seized items under Section 3, Rule 67, Rules of Court; and issue preliminary injunction.
- March 22, 1962: Supreme Court granted preliminary injunction.
- June 29, 1962: Writ partially dissolved as to corporate offices; injunction maintained as to residences of petitioners.
- Petitioners moved for reconsideration and amendment of June 29 Resolution.
Issues
- Whether the search warrants complied with constitutional and procedural requirements (probable cause, particularity).
- Whether petitioners have standing to assail search warrants and seizures made in corporate premises.
- Whether illegally seized papers and effects are admissible in evidence or must be excluded.
- Scope and permanence of the preliminary injunction.
Constitutional and Rule Provisions Involved
- 1935 Constitution, Article III, § 1(3): right against unreasonable searches and seizures; warrants must issue upon probable cause and particularly describe place and things to be seized.
- Rule 122, Sec. 3 (former): warrant must be based on probable cause and particularly describe place and things.
- Revised Rule 126, Sec. 3: warrant must be based on probable cause in connection with one specific offense and describe place and things; no warrant for more than one offense.
Petitioners’ Contentions
- Warrants are general, failing to describe with particularity the documents and things to be seized.
- Warrants issued to “fish” for evi