G.R. No. L-19550; June 19, 1967
Harry S. Stonehill, Robert P. Brooks, John J. Brooks, and Karl Beck, petitioners, vs. Hon. Jose W. Diokno, in his capacity as Secretary of Justice; Jose Lukban, in his capacity as Acting Director, National Bureau of Investigation; Special Prosecutors Pedro D. Cenzon, Efren I. Plana and Manuel Villareal, Jr. and Asst. Fiscal Manases G. Reyes; Judge Amado Roan, Municipal Court of Manila; Judge Roman Cansino, Municipal Court of Manila; Judge Hermogenes Caluag, Court of First Instance of Rizal-Quezon City Branch, and Judge Damian Jimenez, Municipal Court of Quezon City, respondents.

FACTS

Respondent prosecutors applied for, and respondent judges issued, a total of 42 search warrants against petitioners and/or the corporations they officered. The warrants authorized the search of their persons, offices, warehouses, and residences, and the seizure of items described as: “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 (cigarette wrappers).” The warrants alleged these items were connected to violations of “Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and the Revised Penal Code.” Petitioners filed an original action for certiorari, prohibition, mandamus, and injunction, arguing the warrants were null and void for contravening constitutional and procedural requirements, including: (1) lack of particularity in describing things to be seized; (2) seizure of cash not mentioned; (3) issuance to fish for evidence in deportation cases; (4) illegal manner of searches; and (5) failure to deliver seized items to the issuing courts. The Supreme Court initially issued a preliminary injunction but later partially lifted it, allowing the use of items seized from corporate offices while maintaining the injunction for items seized from petitioners’ residences.

ISSUE

1. Whether petitioners have the legal standing to assail the legality of the search warrants and seizures concerning items taken from the corporate offices.
2. Whether the search warrants are constitutionally valid.
3. Whether the illegally seized documents, papers, and things may be used in evidence against the petitioners.

RULING

1. Regarding items seized from corporate offices: Petitioners have no cause of action to challenge the legality of the warrants and seizures for items taken from the offices of the corporations. Corporations have separate juridical personalities distinct from their officers or shareholders. The right to contest an unlawful search and seizure is purely personal and may only be invoked by the party whose rights were directly impaired—here, the corporations themselves. Thus, petitioners cannot object to the use of these corporate documents in evidence against them in their individual capacity.
2. Regarding the validity of the search warrants: The warrants are null and void for violating constitutional requirements. The Constitution mandates that no warrant shall issue except upon probable cause determined by a judge after examination under oath, and must particularly describe the things to be seized. The warrants failed both requirements:
– Lack of Probable Cause: The applications alleged only a general “violation of Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and the Revised Penal Code” without specifying any particular offense or acts committed. Probable cause requires proof of specific acts violating a determinate provision of law, which was absent.
– Lack of Particularity: The warrants authorized the seizure of an overbroad range of items—essentially all business records—without specific description, making them unconstitutional “general warrants.” Upholding such warrants would undermine the constitutional protection against unreasonable searches and seizures.
3. Regarding the use of illegally seized evidence: The documents, papers, and things seized from petitioners’ residences under the void warrants are inadmissible in evidence against them. The Court reaffirmed the exclusionary rule, stating that evidence obtained in violation of constitutional guarantees against unreasonable searches and seizures is “tainted” and must be excluded. To hold otherwise would render constitutional protections meaningless. The preliminary injunction restraining respondents from using these items remains in effect.