Stonehill v. Diokno (1967) Doctrines: 1.

Requisites for issuing Search Warrants: No warrant shal issue but upon probable cause, to be determined by the judge, and that the warrant shall particularly describe the things to be seized.1 2. Search warrants are not issued to discover new evidence but only to verify that such evidence exists. 2 types of invalid search warrants. 1) General warrants-fishing expedition/lack of specificity of objects to be seized, 2)Lack of specificity of crime allegedly committed. 3. Evidence seized in an invalid search is inadmissible for they are Fruits of a Poisonous Tree. SC abandoned Mercado Doctrine which allowed them to be admitted as evidence. 4. General warrants are outlawed to protect the sanctity of the persons right to be secure and also to discourage the police and prosecutors from abusing their power by removing the incentive to violate the right. Ponente: Concepcion, C.J. (1967) Short Version: Search warrants were issued to seize documents and papers showing all business transactions as the subject of the offense in violating Central Bank Laws, Tariff and Customs Laws, Internal Revenue Code, and the RPC. SC Declared the warrants as null and void and the evidence obtained inadmissible, because the warrants were in the nature of General Warrants for it did not describe the items to be seized particularly in relation to a specific crime and the evidence acquired therefore are fruits of a poisoned tree. Facts: 1. Upon application of respondents-prosecutors, several judges issued, on different dates, 32 2 search warrants against petitioner and/ the Corporations of which they were officers to search the persons above-named and/ remises of their offices, warehouses, and/ residences, and to seize documents and papers showing all business transactions as the subject of the offense in violating Central Bank Laws, Tariff and Customs Laws, Internal Revenue Code, and the RPC. 2. Petitioner stand: warrants were null and void for violating Consti3 and (Rules of Court)RoC.4 a. They do not describe with particularit the documents/things to be seized b. Cash money not mentioned in the warrants were actually seized c. They were issued to fish evidence d. searches and seizures were made in an illegal manner e. Things seized were not delivered to the court 3. Respondents stand: a. Search warrants were valid and issued in accord with law b. Defects if any were cured by the petitioners consent c. Evidence is admissible regardless of illegality of search (Moncado v. People) 4. Lower Court initially issued a writ of preliminary injunction-excluding the evidence in question but however partially lifted it as regards to evidence seized from the offices of the corporations. Issue: w/n the warrants were valid and consequently if the evidence can be admitted as evidence? Decision: Search warrants were invalid and the evidence inadmissible. 1. Two groups of evidence : first, those that were seized in the offices of the corporations, second those seized in the residences of the petitioners. 2. Re: First Group: Petitioners Have no cause of action, as the corporations have their own separate personalities distinct from that of Pet. Legality of a seizure can only be contested by the party whose rights have been impaired. 6. Re: Second Group:

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87 Consti Art II Sec 2 Case has a typo, it says 42 but when you count it theres only 32 actually issued warrants 87 Consti Art II Sec 2 RoC Rule 126 Sec.3 No search warrant shall issue for more than one specific offense.

Consti requires probable cause to be determined personally by the judge and particularly describe the things to be seized. a. No Probable Cause - No specific offense had been alleged, and as a consequence it was impossible for the judges to have found the existence of probable cause, for the same presupposes the introduction of competent proof that the party against it who it is sought has performed particular acts or committed specific omissions violating a given provision of our criminal laws. b. No Particularity in the things to be seized seizures of documents pertaining to all business transactions regardless of whether the transactions were legal or illegal. Moncado (non-exclusionary rule) must be abandoned for it is contrary to the spirit of the Consti against unreasonable search and seizures. a. Exclusionary Rule Evidence obtained through invalid search/seizure is inadmissible as evidence. As realized by common law courts this is the only practical means of enforcing the constitutional injunction against unreasonable search and seizure. b. Note that the RPC has a whole Title (7) for offenses done by a Public Officer against a private individual. However this is insufficient, and that is why the court here had now adopted the exclusionary rule. WHEREFORE Moncado abandoned. Warrants relating to the three residences of petitioners are null and void. Evidence obtained therefrom shall be excluded, the writ of injunction made permanent. BUT as to the evidence from the 29 other locations, petition to exclude them is dismissed.