Case Summary (G.R. No. L-19550)
Factual Background
Government prosecutors obtained, on various dates, 42 search warrants directed to peace officers to search petitioners and the premises of certain corporations and residences. The warrants authorized seizure of broadly described items: "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 (cigarette wrappers)." The applications alleged violations only in generic terms (e.g., "violation of Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and the Revised Penal Code") rather than specifying particular offenses or concrete acts. Some cash was reportedly seized though not described in the warrants. Portions of the seized material were used or intended to be used in deportation proceedings.
Procedural Posture and Relief Sought
Petitioners filed an original action in the Supreme Court seeking certiorari, prohibition, mandamus and injunction to quash the search warrants, declare seizures null and void, and require return of seized items in accordance with Rule 67, sec. 3. They also sought a preliminary injunction to restrain respondents from using seized effects or copies in deportation proceedings. Respondent-prosecutors replied claiming warrants were valid, defects (if any) were cured by consent, and that seized effects remained admissible despite any illegality. The Supreme Court granted a preliminary injunction (March 22, 1962) but, by June 29, 1962 resolution, partially dissolved it as to corporate premises while maintaining the injunction as to items seized from petitioners’ residences.
Legal Issues Presented
Primary legal questions were: (1) whether the warrants and the searches and seizures issued and executed under them violated the constitutional protection against unreasonable searches and seizures by lacking particularity and probable cause; (2) whether the breadth of the warrants rendered them general warrants; (3) whether items not described (e.g., cash) could lawfully be seized; (4) whether seized items could be used in evidence notwithstanding alleged unlawfulness; and (5) the petitioners’ standing to challenge seizures from corporate premises.
Court’s Analysis on Standing Regarding Corporate Premises
The Court held that petitioners had no cause of action to challenge seizures made at the corporations’ offices because those entities have personalities separate and distinct from the petitioners, regardless of share ownership or corporate offices held. The Court reaffirmed the settled principle that only a party whose rights were directly invaded by a seizure may contest its legality; objections to unlawful search and seizure are personal and cannot be asserted by third parties. Consequently, documents and other effects seized from corporate offices could not be objected to by petitioners in their individual capacities; any challenge to admissibility of those materials belonged to the corporations.
Court’s Analysis on Validity of Warrants and Particularity Requirement (Residences)
As to items seized from the petitioners’ residences, the Court found substantial constitutional defects. The warrant applications alleged only broad categories of statutory violations without specifying particular offenses or concrete acts by named individuals. The Court emphasized two constitutional requisites: (1) warrants must issue only upon probable cause as determined by the judge after examination under oath or affirmation; and (2) warrants must particularly describe the place to be searched and the persons or things to be seized. The applications’ abstract allegations precluded a judicial finding of probable cause because probable cause presupposes competent proof that a specific offense has been committed by particular acts or omissions. The Court concluded that the warrants were so broad in describing the things to be seized (authorizing seizure of records relating to "all business transactions" whether legal or illegal) that they amounted to general warrants outlawed by the constitutional provision protecting domiciliary and privacy rights.
Abandonment of Prior Non-Exclusionary Doctrine and Adoption of the Exclusionary Rule
The Court unanimously abandoned the rule previously enunciated in Moncado v. People, which permitted admission of evidence obtained through unconstitutional searches while relying on other remedies (e.g., actions for damages) to vindicate constitutional rights. The Court adopted the exclusionary rule, concluding that exclusion of evidence obtained by unconstitutional searches is the only practical and effective means to enforce the constitutional protection against unreasonable searches and seizures. The opinion reviewed and relied upon authorities demonstrating that permitting unlawfully obtained evidence would render the constitutional guarantee hollow, and that exclusion serves as the necessary deterrent against official lawlessness.
Holdings and Relief Granted
The Supreme Court held that: (a) the doctrine of Moncado (non-exclusion of unlawfully obtained evidence) was abandoned; (b) the warrants for searches of the three specified residences were null and void; (c) the searches and seizures conducted in those residences were illegal; (d) the preliminary injunction previously issued with respect to the items seized from those residences was made permanent; and (e) the petition for relief was dismissed and writs denied insofar as they related to documents and items seized from the twenty-nine corporate and other non-residential premises identified in the June 29, 1962 resolution. T
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Facts of the Case
- The action arises from the issuance, on different dates between March 3 and March 9, 1962, of a total of 42 search warrants directed to peace officers to search and seize property from petitioners and/or corporations of which they were officers.
- The search warrants were applied for by government officers named in the margin (Respondent-Prosecutors): Hon. Jose W. Diokno (Secretary of Justice), Jose Lukban (Acting Director, NBI), Special Prosecutors Pedro D. Cenzon, Efren I. Plana, Manuel Villareal, Jr., and Assistant Fiscal Manases G. Reyes.
- The warrants named as persons to be searched the petitioners: Harry S. Stonehill, Robert P. Brooks, John J. Brooks and Karl Beck.
- The warrants were directed to search persons and premises (offices, warehouses, residences) and to seize broadly described items: "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 (cigarette wrappers)" — described in the applications as "the subject of the offense; stolen or embezzled and proceeds or fruits of the offense," or "used or intended to be used as the means of committing the offense."
- The alleged offenses in the applications were stated generally as violations of "Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and the Revised Penal Code," without specifying particular provisions or specific acts.
- Petitioners allege the search warrants are null and void for multiple reasons including lack of particularity, seizure of cash not described, use of searches to fish for evidence in pending deportation cases, illegal manner of searches/seizures, and failure to deliver seized items to issuing courts for lawful disposition.
Corporations and Premises Involved (as named in source)
- Corporations whose offices/warehouses were among places searched included: U. S. Tobacco Corporation; Atlas Cement Corporation; Atlas Development Corporation; Far East Publishing Corporation (Evening News); Investment Inc.; Industrial Business Management Corporation (IBMC); General Agricultural Corporation; American Asiatic Oil Corporation; Investment Management Corporation; Holiday Hills, Inc.; Republic Glass Corporation; Industrial and Business Management Corporation; United Housing Corporation; The Philippine Tobacco-Flue-Curing and Redrying Corporation; Republic Real Estate Corporation; Merconsel Corporation.
- The contested warrants related to searches of corporate offices/warehouses as well as the petitioners' residences. The Court’s June 29, 1962 Resolution listed 29 corporate/offices/other premises from which the injunction was lifted and three residences for which the preliminary injunction was maintained.
Procedural History
- Petitioners filed an original action for certiorari, prohibition, mandamus and injunction with the Supreme Court on March 20, 1962, praying among other reliefs that the search warrants be quashed and that seized items be returned pursuant to Section 3, Rule 67, Rules of Court.
- Petitioners also sought a writ of preliminary injunction restraining Respondent-Prosecutors and agents from using seized effects, or any copies, in deportation cases R-953 and R-955.
- Respondents (prosecutors) answered alleging: (1) the warrants were valid and issued in accordance with law; (2) any defects were cured by petitioners' consent; and (3) seized effects were admissible in evidence against petitioners notwithstanding any illegality.
- On March 22, 1962, the Supreme Court issued the writ of preliminary injunction prayed for by petitioners.
- By resolution dated June 29, 1962, the preliminary injunction was partially lifted insofar as papers, documents and things seized from the offices of the corporations were concerned (29 enumerated premises), but the injunction was maintained with respect to papers, documents and things seized from the residences of petitioners (three specified residences).
Petitioners’ Principal Allegations and Grounds for Relief
- The search warrants were effectively general warrants, lacking the necessary particularity demanded by the Constitution and Rules of Court.
- The warrants did not describe with particularity the documents, books and things to be seized; instead they authorized seizure of records showing "all business transactions," thereby authorizing seizure of wide-ranging and unspecified materials.
- Cash money not mentioned in the warrants was actually seized.
- The warrants and resulting searches were used to "fish" for evidence to be used in deportation proceedings against petitioners rather than to pursue a specific offense supported by probable cause.
- Searches and seizures were conducted illegally and in an improper manner.
- Seized documents, papers and cash money were not delivered to the issuing courts for disposition as required by law.
Respondents’ Principal Contentions
- The contested search warrants were valid and had been issued in accordance with law.
- Any defects in the warrants were cured by the consent of petitioners.
- In any event, the effects seized were, or should be, admissible in evidence against petitioners regardless of alleged illegality of searches and seizures.
Legal Standards and Constitutional Provision Applied
- The Court invoked Section 1, paragraph 3, Article III of the Constitution: "The right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures shall not be violated, and no warrants shall issue but upon probable cause, to be determined by the judge after examination under oath or affirmation of the complainant and the witnesses he may produce, and particularly describing the place to be searched, and the persons or things to be seized."
- Two requirements emphasized: (1) warrants shall issue only upon probable cause determined by a judge after examination under oath; and (2) the warrant must particularly describe the things to be seized.
- The Court observed that the contested warrants failed both requirements: applications alleged offenses only in general terms (no specific offense identified), and the description of items to be seized was overly broad (records of "all business transactions"), amounting to general warrants.
Court’s Analysis Regarding Corporate Premises vs. Residences
- The Court divided the seized items into two major groups:
- (a) items seized from offices/premises of the corporations named; and
- (b) items seized from the residences of petitioners.
- As to group (a) — corporate offices/premises:
- The Court held petitioners had no cause of action to assail the legality of the warrants or seizures made at the corporate premises because corporations have separate legal personalities distinct from the individual petitioners regardless of shareholdings or offices held.
- The right to object to an unlawful search and seizure is personal to the party whose rights were invaded; corporate officers cannot assert the corporation's objection in their individual capacity.
- The Court relied on authorities (including cited U.S. cases and prior Philippine decisions) that the objection to an unlawful search and seizure is purely personal and cannot be availed of by third parties.
- Consequently, petitioners could not validly object to the use in evidence against them of documents seized from the corporate offices; the objection belonged to the corporations.
- As to group (b) — residences of petitioners:
- The Court noted its June 29, 1962 resolution had maintained the preliminary injunction as to documents seized from the three residen