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Case digest · Search and seizure; exclusionary rule
Stonehill vs. Diokno
Forty-two search warrants for records of “all business transactions.” Who may object to the seizure of a corporation’s papers?
Facts
March 3–9, 1962
On the application of government prosecutors, several judges issued a total of 42 search warrants against Harry S. Stonehill, Robert P. Brooks, John J. Brooks and Karl Beck and/or the corporations of which they were officers.
What the warrants covered
The warrants ordered the seizure of books of accounts, financial records, vouchers, correspondence, receipts, ledgers, journals, typewriters, and other documents and/or papers “showing all business transactions,” in connection with an offense that the applications described only as “violation of Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and the Revised Penal Code.”
The petition
On March 20, 1962, the petitioners asked the Supreme Court to declare the warrants void and to stop the prosecutors from using the seized effects in deportation cases filed against them. The Court issued a preliminary injunction on March 22, 1962.
June 29, 1962
The Court partially lifted the injunction as to the papers seized from the corporations’ offices, but kept it in place for the papers seized in the petitioners’ residences.
Issue
Were the warrants valid, could the seized papers be used in evidence, and who may object to the seizure of corporate papers?
Ruling
The warrants for the petitioners’ three residences were void general warrants, and the Moncado doctrine was abandoned. But the officers could not object to the papers seized from the corporations’ offices.
The applications alleged no specific offense, only abstract violations of several laws, so no judge could have found probable cause. The warrants also failed to describe the things to be seized with particularity: they covered records of all business transactions, legal or illegal. The Court unanimously abandoned the Moncado doctrine, which had allowed illegally seized evidence to be used, and adopted the exclusionary rule. It declared the warrants for the three residences void and made the injunction over the papers seized there permanent, and it denied the petitioners’ motion for reconsideration. As to the papers seized in the 29 offices and other premises, it dismissed the petition: the corporations have personalities separate and distinct from their officers, and the right to object belongs to the corporations alone.
“…the right to object to the admission of said papers in evidence belongs exclusively to the corporations, to whom the seized effects belong, and may not be invoked by the corporate officers in proceedings against them in their individual capacity.”
Doctrine
The legality of a seizure “can be contested only by the party whose rights have been impaired thereby,” and “the objection to an unlawful search and seizure is purely personal and cannot be availed of by third parties.” On admissibility, the Court held that “the position taken in the Moncado case must be abandoned.”
Bar tip
Ask whose right was violated. Officers and stockholders cannot invoke the corporation’s right against the seizure of corporate papers, but they can challenge the search of their own homes. The exclusionary rule this case adopted is now written into the 1987 Constitution, Article III, Section 3(2).
Hear it explained
Ano Ba Talaga ang Corporation?, at 1:38
This digest is general legal information for education, not legal advice, and it is not a substitute for reading the decision. Quoted passages are taken word for word from the full text.