Вы находитесь на странице: 1из 2

University of the Philippines College of Law

Block F2022

Case No. G.R. No. L-19550 | June 19, 1967


Case Name Stonehill v Diokno
Ponente Concepcion, CJ

RELEVANT FACTS

 The respondent judges issued numerous warrants of arrest against the petitioners, who are officers and
employees of various corporations. The judges authorized the police to search the persons or premises
of their offices and respective residences and to seize personal properties such as account books,
financial records, receipts, balance sheet and other business transactions.
 The Judges claimed that these warrants are valid because:
o They were issued in accordance with law.
o Seizure was done because the petitioners allegedly committed violations of Central Bank Laws,
Tariff and Customs Laws, the RPC and the Internal Revenue Code.
o Objects seized during the searches are therefore admissible as evidence against petitioners,
regardless of the alleged illegality of the search.
 Petitioners claim that the search warrants are invalid because:
o The issued warrants do not adequately describe the documents and records to be seized.
o Objects not mentioned in the warrant, such as money, were seized as well.
o The seized artifacts were not brought back to the issuing court.

ISSUE

 W/N the seizure of the documents found in the offices of the corporations valid
 W/N the seizure of the documents found in the residences of the petitioners is valid – NO
 Under the 1935 Constitution, no warrant shall issue but upon probable cause to be determined by a
judge.
o Furthermore, it requires that a warrant shall particularly describe the objects to be seized.
 Neither of these 2 requirements were met by the contested warrants.
o The warrants state that the petitioners committed violations of Central Bank Laws, Tariff and
Customs Laws, the RPC and the Internal Revenue Code, but no specific offense was alleged.
o Thus it was impossible for the respondent-judges to have found the existence of probable
cause since the petitioners were not alleged to have done any specific act or omission which
violated aforementioned laws.
 The warrants allowed the search and seizure of documents pertaining to ALL business transactions,
regardless of its legal or illegal nature.
o This violates the constitutional requirement that the objects to be seized must be particularly
described in the warrant.
o “General warrants” are prohibited by the constitution, because allowing such would violate the
privacy of communication and correspondence and will leave persons at the mercy of the whims
of the police.

RATIO DECIDENDI

Issue Ratio
W/N the seizure of the Yes.
documents found in the
offices of the corporations Petitioners do not have cause of action to assail the legality of the warrants
University of the Philippines College of Law
Block F2022
valid and seizures because they have separate and distinct personalities from
corporations they are part of. The legality of the seizure can only be assailed
by the corporations who own the seized objects.
W/N the seizure of the No.
documents found in the
residences of the petitioners Under the 1935 Constitution, no warrant shall be issued unless upon
is valid probable cause is determined by a judge. It requires that a warrant shall
comprehensively describe the objects to be seized. Neither of these
requirements were met by the contested warrants. The warrants state that
the petitioners committed violations of Central Bank Laws, Tariff and Customs
Laws, the RPC and the Internal Revenue Code, but no specific offense was
alleged. It was therefore impossible for the judges to have found the
existence of probable cause since the petitioners were not alleged to have
committed any specific act or omission which violated such laws.

The warrants allowed the search and seizure of documents pertaining to ALL
business transactions, regardless of its legality. This violates the constitutional
requirement that the objects to be seized must be described in the warrant.
“General warrants” are prohibited by the constitution as it would be violative
of the privacy of communication and correspondence.

RULING
 Warrants for the search of three (3) residences of herein petitioners, as specified in the Resolution of
June 29, 1962 are null and void;
 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 of herein
petitioners is hereby made permanent
 Writs prayed for are granted, insofar as the documents, papers and other effects so seized in the
aforementioned residences are concerned;
 Motion for Reconsideration and Amendment should be, as it is hereby, denied; and that the petition
herein is dismissed and the writs prayed for denied, as regards the documents, papers and other effects
seized in the twenty-nine (29) places enumerated in the same Resolution, without special
pronouncement as to costs.

SEPARATE OPINIONS

Castro, concurring/dissenting

The petitioners have full standing to move for the quashing of all the warrants regardless of whether these were
directed against residences in the narrow sense of the word, as long as the documents were personal papers of
the petitioners or (to the extent that they were corporate papers) were held by them in a personal capacity or
under their personal control.

Вам также может понравиться