Tuesday, June 10, 2014

Stonehill et al. v. Diokno et al. case brief summary

Stonehill et al. v. Diokno et al. case brief summary
20 SCRA 383, June 19, 1967

FACTS: Respondents issued, on different dates, 42 search warrants against petitioners personally, and/or corporations for which they are officers directing peace officers to search the persons of petitioners and premises of their offices, warehouses and/or residences to search for personal properties “books of accounts, financial records, vouchers, correspondence, receipts, ledgers, journals, portfolios, credit journals, typewriters, and other documents showing all business transactions including disbursement receipts, balance sheets and profit and loss statements and Bobbins(cigarettes)” as the subject of the offense for violations of Central Bank Act, Tariff and Customs Laws, Internal Revenue Code, and Revised Penal Code.
Upon effecting the search in the offices of the aforementioned corporations and on the respective residences of the petitioners, there seized documents, papers, money and other records. Petitioners then were subjected to deportation proceedings and were constrained to question the legality of the searches and seizures as well as the admissibility of those seized as evidence against them.
On March 20, 1962, the SC issued a writ of preliminary injunction and partially lifted the same on June 29, 1962 with respect to some documents and papers.
ISSUE: (1) Were the search warrants and the search and seizures valid and issued in accordance with law? and
(2) If not, can said documents, papers and things be used against petitioners?

  1. Search warrants issued were violative of the Constitution and the Rules, thus, illegal or being general warrants. There is no probable cause and warrant did not particularly specify the things to be seized. The purpose of the requirement is to avoid placing the sanctity of the domicile and the privacy of communication and correspondence at the mercy of the whims, caprice or passion of peace officers.
  2. Document seized from an illegal search warrant is not admissible in court based on the exclusionary rule as stated in Article III, Section 3 of the Constitution. However, they could not be returned, except if warranted by the circumstances.
  3. Petitioners were not the proper party to question the validity and return of those taken from the corporations for which they acted as officers as they are treated as personality different from that of the corporation.

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