G.R. No. 163087 February 20, 2006
SILAHIS INTERNATIONAL HOTEL, INC. and JOSE MARCEL PANLILIO, Petitioners, vs. ROGELIO S. SOLUTA, JOSELITO SANTOS, EDNA BERNATE, VICENTA DELOLA, FLORENTINO MATILLA, and GLOWHRAIN-SILAHIS UNION CHAPTER, Respondents.

FACTS

Petitioner Jose Marcel Panlilio, Vice President for Finance of co-petitioner Silahis International Hotel, authorized a surveillance of the hotel employees’ union office based on reports of illegal activities. On January 11, 1988, Panlilio, security personnel, and others entered the union office. Petitioners claim entry and search were with union officer Henry Babay’s permission, resulting in the discovery of marijuana. Respondents, union officers and members, present a contrary version: unknown men forcibly opened the office at dawn, and later, Panlilio’s group conducted a warrantless search over Babay’s objection, finding the marijuana. This led to the criminal prosecution of union officers for violation of the Dangerous Drugs Act, but the Regional Trial Court acquitted them, noting the suspicious circumstances of the confiscation.

ISSUE

Whether petitioners are civilly liable for damages under Article 32 of the Civil Code for violating respondents’ constitutional right against unreasonable search.

RULING

Yes, petitioners are civilly liable. The Supreme Court affirmed the Court of Appeals’ decision. Article 32 of the Civil Code provides a civil action for damages for violations of constitutional rights, such as the right against unreasonable search, even when committed by private individuals. The Court clarified that this liability is distinct from the exclusionary rule in criminal law, which may not apply to evidence obtained by private persons. Here, the search of the union office was conducted without a warrant and absent any exigent circumstance justifying a warrantless search, such as a lawful arrest. The act constituted a violation of a constitutional right. Consequently, petitioners, as private individuals who orchestrated and participated in the illegal search, are liable for damages under Article 32 in relation to Article 2219(6) of the Civil Code. The award of moral damages was proper due to the mental anguish and social humiliation suffered by the respondents from the baseless criminal prosecution that stemmed from the illicit search.