Constitutional Law: Stonehill v Diokno

Stonehill v Diokno

Facts:

Forty-two (42) search warrants were issued at different dates against petitioners and the corporations of which they were officers. Peace officers were directed to search the persons of the petitioners and/or their premises of their offices, warehouses and/or residences. 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 were to be seized.

Petitioner contends that the issued search warrants were null and void as having contravened the Constitution and the Rules of Court for, among others, it did not describe the documents, books and things to be seized PARTICULARLY.

Issue:

Whether or not the search warrant has been validly issued.

Whether or not the seized articles may be admitted in court.

Held:

The authority of the warrants in question may be split in two major groups: (a) those found and seized in the offices of the corporations; and (b) those found and seized in the residences of the petitioners.

The petitioners have no cause of action against the contested warrants on the first major group. This is because corporations have their respective personalities, separate and distinct from the personality of their officers, directors and stockholders. The legality of a seizure can be contested only by the party whose rights have been impaired, the objection to an unlawful search and seizure purely being personal cannot be availed by third parties.

As to the second major group, two important questions need be settled: (1) whether the search warrants in question, and the searches and seizures made under authority thereof, are valid or not; and (2) if the answer is no, whether said documents, papers and things may be used in evidence against petitioners.

The Constitution protects the rights of the people from unreasonable searches and seizure. Two points must be stressed in connection to this constitutional mandate: (1) no warrant shall be issued except if based upon probable cause determined personally by the judge by the manner set in the provision; and (2) the warrant shall describe the things to be seized with particularly.

In the present case, no specific offense has been alleged in the warrant’s application. The averments of the offenses committed were abstract and therefore, would make it impossible for judges to determine the existence of probable cause. Such impossibility of such determination naturally hinders the issuance of a valid search warrant.

The Constitution also requires the things to be seized described with particularity. This is to eliminate general warrants.

The Court held that the warrants issued for the search of three residences of petitioners are null and void.