G.R. No. L-824; January 14, 1948
Hilario Camino Moncado, petitioner, vs. The People’s Court and Juan M. Ladaw, as Special Prosecutor, respondents.

FACTS

Petitioner Hilario Camino Moncado was accused of treason. On April 4, 1945, he was arrested without a warrant by members of the U.S. Army CIC and detained. A week later, CIC officers, also without a search warrant, searched his Manila residence in the presence of his wife and seized several documents. On June 27, 1946, Moncado filed a motion before the People’s Court for the return of these documents, arguing they were obtained through an illegal search and seizure in violation of his constitutional rights. The People’s Court denied his motion, citing the ruling in Alvero vs. Dizon. Moncado then filed this original petition for certiorari, seeking to annul the People’s Court’s order, compel the return of the documents, and prohibit their use as evidence against him.

ISSUE

Whether documents seized in violation of constitutional guarantees against unreasonable searches and seizures are admissible as evidence in a criminal trial.

RULING

No. The Supreme Court denied the petition, upholding the admissibility of the illegally seized evidence.
The Court distinguished the case from Alvero vs. Dizon, noting that when the documents were seized on April 11, 1945, the Commonwealth government had already been fully restored by General MacArthur on February 27, 1945, and was exercising its constitutional powers without limitation in Manila. The constitutional guarantees were in force.
However, the Court adhered to the then-prevailing doctrine in Philippine jurisprudence that the admissibility of evidence is not affected by the illegality of the means through which it was obtained. The Constitution provides the right against unreasonable searches and seizures, and public officials who violate it may be held liable. Nevertheless, the Rules of Court (Rule 123) at the time did not classify illegally obtained evidence as incompetent or inadmissible. The constitutional limitation operates as a restriction on the powers of government (legislative, executive, and judicial) to authorize or justify unreasonable searches, but it does not automatically render evidence obtained thereby inadmissible in court.
The Court declined to adopt the U.S. Federal rule established in Weeks vs. United States, which required the exclusion of such evidence, noting that this exclusionary rule was not the unanimous doctrine in the United States and was not followed in many states.
(J. Briones and J. Perfecto dissented, advocating for the adoption of the Weeks doctrine to give full force to the constitutional guarantee, especially in the young Philippine democracy.)

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