Case Digest of Stonehill V Diokno 20 SCRA 383

Stonehill vs Diokno

20 SCRA 383
CONCEPCION, C.J.

Fact:

 Stonehill et al, herein petitioners, and the corporations they form were alleged to have committed acts in
“violation of Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and Revised Penal
Code.”
 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(cigarette wrappers)” as the subject of
the offense for violations of Central Bank Act, Tariff and Customs Laws, Internal Revenue Code, and
Revised Penal Code.
 The documents, papers, and things seized under the alleged authority of the warrants in question may be
split into (2) major groups, namely:
a) those found and seized in the offices of the aforementioned corporations and
b) those found seized in the residences of petitioners herein.
 Petitioners averred that the warrant is null and void for being violative of the constitution and the Rules of
court by:
a) not describing with particularity the documents, books and things to be seized;
b) money not mentioned in the warrants were seized;
c) the warrants were issued to fish evidence for deportation cases filed against the petitioner;
d) the searches and seizures were made in an illegal manner; and
e) the documents paper and cash money were not delivered to the issuing courts for disposal in
accordance with law.
 The prosecution counters that the search warrants are valid and issued in accordance with law; The
defects of said warrants were cured by petitioners consent; and in any event, the effects are admissible
regardless of the irregularity.
Issue:
Whether or not the search warrant is Valid
Ruling:
 NO the search warrant is invalid. The SC ruled in favor of petitioners. The constitution protects the
people’s right against unreasonable search and seizure. It provides; (1) that no warrant shall issue but
upon probable cause, to be determined by the judge in the manner set forth in said provision; and (2) that
the warrant shall particularly describe the things to be seized. In the case at bar, none of these are met.
 The warrant was issued from mere allegation that petitioners committed a “violation of Central Bank
Laws, Tariff and Customs Laws, Internal Revenue (Code) and Revised Penal Code.” In other words, no
specific offense had been alleged in said applications. The averments thereof with respect to the offense
committed were abstract.
 As a consequence, 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.
 As a matter of fact, the applications involved in this case do not allege any specific acts performed by
herein petitioners. It would be a legal heresy, of the highest order, to convict anybody of a “violation of
Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and Revised Penal Code,” — as
alleged in the aforementioned applications — without reference to any determinate provision of said laws
or codes.
 The warrants authorized the search for and seizure of records pertaining to all business transactions of
petitioners regardless of whether the transactions were legal or illegal.
 Thus, openly contravening the explicit command of the 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.
 However, SC emphasized that petitioners cannot assail the validity of the search warrant issued against
their corporation because petitioners are not the proper party.
 The petitioners have no cause of action to assail the legality of the contested warrants and of the seizures
made in pursuance thereof, for the simple reason that said corporations have their respective
personalities, separate and distinct from the personality of herein petitioners, regardless of the amount of
shares of stock or of the interest of each of them in said corporations, and whatever the offices they hold
therein may be.8 Indeed, it is well settled that the legality of a seizure can be contested only by the party
whose rights have been impaired thereby and that the objection to an unlawful search and seizure is
purely personal and cannot be availed of by third parties.

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Stonehill vs Diokno

Whether or not the search warrant is Valid

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