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# AK432252
Stonehill vs. Diokno

This case involves a petition challenging the validity of 42 search warrants issued against petitioners and the corporations they managed for alleged violations of various laws. Petitioners argued the warrants were general warrants and sought to suppress the evidence seized. The Supreme Court declared the warrants issued for the petitioners' residences null and void for violating constitutional requirements of probable cause and particularity, adopted the exclusionary rule for illegally seized evidence (abandoning the Moncado doctrine), but held that petitioners lacked standing to challenge the warrants and seizures conducted in the corporate offices, as corporations have distinct legal personalities.

Primary Holding

Search warrants must be issued based upon probable cause for one specific offense and must particularly describe the things to be seized to be constitutionally valid; evidence obtained in violation of the constitutional right against unreasonable searches and seizures is inadmissible (exclusionary rule); the right to object to an unlawful search and seizure is personal and cannot be invoked by corporate officers for searches conducted on corporate premises.

Background

Government prosecutors applied for and were granted 42 search warrants by various judges against the petitioners (corporate officers) and the corporations they managed. The applications alleged violations of Central Bank Laws, Tariff and Customs Laws, the Internal Revenue Code, and the Revised Penal Code, leading to searches of offices, warehouses, and residences, and the seizure of numerous documents and items.

History

  1. Petitioners filed an original action for certiorari, prohibition, mandamus, and injunction with the Supreme Court (March 20, 1962).

  2. Supreme Court issued a writ of preliminary injunction restraining the use of seized items (March 22, 1962).

  3. Supreme Court partially lifted the injunction concerning items seized from corporate offices but maintained it for items seized from petitioners' residences (Resolution of June 29, 1962).

  4. Petitioners filed a Motion for Reconsideration and Amendment of the Resolution of June 29, 1962.

Facts

  • Respondent prosecutors applied to respondent judges for search warrants against petitioners (Harry S. Stonehill, Robert P. Brooks, John J. Brooks, Karl Beck) and multiple corporations they were officers of.
  • Between March 3-9, 1962, a total of 42 search warrants were issued, directing peace officers to search the named persons, corporate offices, warehouses, and residences.
  • The warrants authorized the 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 disbursements receipts, balance sheets and profit and loss statements and Bobbins (cigarette wrappers)."
  • The applications described the alleged offenses very generally as "violation of Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and the Revised Penal Code."
  • Searches were conducted, and various documents, papers, and cash money (which was not mentioned in the warrants) were seized.
  • The seized items were intended to be used by respondent prosecutors in deportation cases filed against the petitioners.
  • The items seized could be categorized into two groups: (a) those seized from corporate offices and premises, and (b) those seized from the petitioners' personal residences.

Arguments of the Petitioners

  • The search warrants are null and void because they do not describe with particularity the documents, books, and things to be seized, making them general warrants.
  • The warrants were issued without probable cause for any specific offense, as the applications only mentioned general violations of laws.
  • Cash money was seized even though it was not mentioned in the warrants.
  • The warrants were improperly issued to fish for evidence against petitioners in deportation cases.
  • The searches and seizures were conducted in an illegal manner.
  • The seized items were not delivered to the issuing courts as required by law.
  • The illegally seized items should be returned, and prosecutors should be enjoined from using them as evidence.
  • Petitioners have standing to challenge the seizures in corporate offices because some items were personal belongings or under their exclusive control, and the warrants were directed at them personally (raised in Motion for Reconsideration).

Arguments of the Respondents

  • The contested search warrants are valid and were issued in accordance with law.
  • Any defects in the warrants were cured by the petitioners' alleged consent to the searches.
  • Even if the searches and seizures were illegal, the seized items are still admissible in evidence against the petitioners, citing the Moncado vs. People's Court doctrine.

Issues

  • Whether the petitioners have a cause of action to challenge the legality of the search warrants and seizures made in the corporate offices.
  • Whether the search warrants issued for the petitioners' residences are valid.
  • Whether the documents, papers, and effects seized are admissible in evidence against the petitioners.

Ruling

  • Petitioners have no cause of action to assail the legality of the warrants and seizures related to the corporate offices because corporations have legal personalities separate from their officers; the right against unreasonable search and seizure is personal and cannot be invoked by third parties (corporate officers for corporate property).
  • The search warrants issued for the petitioners' residences are null and void because they failed to meet the constitutional requirements of probable cause (no specific offense alleged) and particularity of description (items to be seized were described too broadly), making them general warrants.
  • The documents, papers, and effects seized from the corporate offices are admissible in evidence against the petitioners in the deportation cases, as the right to object belongs exclusively to the corporations.
  • The documents, papers, and effects seized from the petitioners' residences are inadmissible in evidence because they were obtained through illegal searches and seizures violating the Constitution (applying the exclusionary rule).
  • The doctrine established in Moncado vs. People's Court, which permitted the admission of illegally seized evidence, is abandoned.
  • The Court denied the petitioners' Motion for Reconsideration regarding items seized from corporate premises, finding their arguments on personal possession/control insufficient or raised too late, leaving the matter open for future determination.
  • The writ of preliminary injunction preventing the use of evidence seized from the petitioners' residences is made permanent.

Doctrines

  • Right Against Unreasonable Searches and Seizures: Definition: A constitutional guarantee protecting persons, houses, papers, and effects from arbitrary intrusions by the government. Application: The Court held this right was violated by the general warrants issued for the petitioners' residences.
  • Probable Cause Requirement: Definition: The necessity for facts and circumstances sufficient to induce a reasonably discreet and prudent person to believe that an offense has been committed and that the objects sought are connected with the offense. Application: The Court found this lacking as the warrant applications failed to allege any specific offense, only broad categories of law violations.
  • Particularity Requirement: Definition: The constitutional mandate that a search warrant must particularly describe the place to be searched and the persons or things to be seized. Application: The Court ruled the warrants invalid because the description of items ("Books of accounts... showing all business transactions...") was too general, allowing for a fishing expedition.
  • General Warrants: Definition: Warrants that do not sufficiently specify the offense, the place to be searched, or the things to be seized, outlawed by the Constitution. Application: The Court classified the contested warrants as void general warrants due to the lack of specificity regarding the offense and the items.
  • Exclusionary Rule: Definition: A legal principle holding that evidence collected or analyzed in violation of the defendant's constitutional rights is generally inadmissible in a court of law. Application: The Court explicitly adopted this rule, abandoning the prior Moncado doctrine, and declared evidence seized from petitioners' residences inadmissible.
  • Separate Corporate Personality: Definition: The legal principle that a corporation has a legal identity distinct from its owners, shareholders, or officers. Application: The Court used this doctrine to deny petitioners standing to object to searches of corporate premises, as the right violated belonged to the distinct corporate entity.
  • Personal Nature of Constitutional Rights: Definition: The principle that certain constitutional rights, like the right against unreasonable searches and seizures, are personal and cannot be invoked vicariously or by third parties. Application: This was the basis for denying petitioners standing regarding the corporate seizures; only the party whose rights were directly violated (the corporations) could object.
  • Standing (Locus Standi): Definition: The legal right of a party to challenge the conduct of another party in court. Application: The Court held petitioners had standing concerning their residences but lacked standing concerning the corporate premises because their personal rights were not directly violated by the search of corporate property.

Key Excerpts

  • "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." (Quoting the Constitution)
  • "...it was impossible for the judges who issued the warrants to have found the existence of probable cause, for the same presupposes the introduction of competent proof that the party against whom it is sought has performed particular acts, or committed specific omissions, violating a given provision of our criminal laws."
  • "The warrants sanctioned the seizure of all records of the petitioners and the aforementioned corporations, whatever their nature, thus openly contravening the explicit command of our Bill of Rights - that the things to be seized be particularly described - as well as tending to defeat its major objective: the elimination of general warrants."
  • "...we are unanimously of the opinion that the position taken in the Moncado case must be abandoned. Said position was in line with the American common law rule, that the criminal should not be allowed to go free merely 'because the constable has blundered'..."
  • "...exclusion is the only practical way of enforcing the constitutional privilege." (Citing Judge Learned Hand)
  • "We hold, therefore, that the doctrine adopted in the Moncado case must be, as it is hereby, abandoned; that the warrants for the search of three (3) residences of herein petitioners... are null and void; that the searches and seizures therein made are illegal; that the writ of preliminary injunction heretofore issued, in connection with the documents, papers and other effects thus seized in said residences... is hereby made permanent..."

Precedents Cited

  • Moncado vs. People's Court (80 Phil. 1): Cited as the previous Philippine doctrine allowing admissibility of illegally seized evidence, which the Court explicitly abandoned in this decision.
  • A. Guckenheimer & Bros. Co. vs. United States (3 F. 2d, 786): Cited to support the principle that the objection to unlawful seizure is personal and cannot be claimed by defendants whose personal property or privacy was not disturbed; specifically, corporate officers cannot object for the corporation.
  • Remus vs. United States (291 F. 501): Cited alongside Guckenheimer to illustrate that the admissibility question regarding unlawfully seized corporate papers does not extend to personal defendants (officers).
  • Weeks vs. United States (232 U.S. 383): Cited as the origin of the exclusionary rule in the U.S. federal system, emphasizing that using illegally seized evidence nullifies the constitutional protection.
  • Mapp vs. Ohio (367 U.S. 643): Cited extensively as the U.S. Supreme Court case that applied the exclusionary rule to the States, arguing that the right to privacy requires the exclusion of illegally obtained evidence as its essential sanction.
  • Wolf vs. Colorado (338 U.S. 25): Discussed in the context of Mapp, as the case that initially applied the Fourth Amendment privacy right to the States but declined to impose the exclusionary rule, a stance later overturned by Mapp.
  • Boyd vs. United States (116 U.S. 616) & Silverthorne Lumber Co. vs. United States (251 U.S. 385): Mentioned in the Mapp quote as foundational cases linking the exclusionary rule to the right against unreasonable searches.
  • US cases on standing (e.g., Newingham, Lesis, Dooley, Rouda, Gass, People vs. Rubio): Cited generally to support the rule that the legality of a seizure can only be contested by the party whose rights were impaired and that the objection is personal.

Provisions

  • Philippine Constitution (1935), Article III, Section 1, paragraph 3: The provision guaranteeing the right against unreasonable searches and seizures, requiring probable cause and particularity for warrants. This is the central provision violated by the warrants.
  • Rules of Court (Old), Rule 122, Section 3: The former rule on search warrants, which the Court noted it had amended to strengthen requirements.
  • Rules of Court (Revised), Rule 126, Section 3: The rule applicable at the time of the decision, explicitly requiring probable cause "in connection with one specific offense" and prohibiting issuance for more than one specific offense, reflecting the Court's stricter stance post-Moncado era abuses.
  • Rules of Court (Old), Rule 67, Section 3: Referenced in petitioners' prayer regarding the return of seized items (likely referring to provisions on disposition of property in certiorari/prohibition, though Rule 67 relates to Certiorari/Prohibition, not specifically property return which is often under criminal procedure rules like Rule 126).
  • U.S. Constitution, Fourth Amendment: Implicitly referenced throughout the decision, particularly when discussing U.S. jurisprudence on searches, seizures, and the exclusionary rule, as the Philippine provision is derived from it.
  • U.S. Constitution, Fourteenth Amendment (Due Process Clause): Mentioned in the context of Mapp vs. Ohio as the mechanism through which the Fourth Amendment's protections (and the exclusionary rule) were applied to the U.S. States.