The petitioners, who were corporate officers, filed a case challenging the validity of search warrants issued against the corporations and the seizure of documents from the corporate offices. The Supreme Court ruled that the petitioners did not have standing to object to the search warrants or seizures made in the corporate offices because corporations have separate legal personalities from their officers. Only the corporations themselves could challenge the legality of seizures of corporate property, not the officers in their individual capacities. Therefore, the petitioners could not prevent the use of the seized documents as evidence against them.
The petitioners, who were corporate officers, filed a case challenging the validity of search warrants issued against the corporations and the seizure of documents from the corporate offices. The Supreme Court ruled that the petitioners did not have standing to object to the search warrants or seizures made in the corporate offices because corporations have separate legal personalities from their officers. Only the corporations themselves could challenge the legality of seizures of corporate property, not the officers in their individual capacities. Therefore, the petitioners could not prevent the use of the seized documents as evidence against them.
The petitioners, who were corporate officers, filed a case challenging the validity of search warrants issued against the corporations and the seizure of documents from the corporate offices. The Supreme Court ruled that the petitioners did not have standing to object to the search warrants or seizures made in the corporate offices because corporations have separate legal personalities from their officers. Only the corporations themselves could challenge the legality of seizures of corporate property, not the officers in their individual capacities. Therefore, the petitioners could not prevent the use of the seized documents as evidence against them.
Title HARRY S. STONEHILL, ROBERT P. BROOKS, JOHN J.
BROOKS and KARL BECK
v. 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, G.R. No. L-19550 June 19, 1967 Ponente CONCEPCION, C.J. Doctrine Constitutional Guarantees of Corporations; Search and Seizure Facts ● Upon application of Respondent-Prosecutors, Respondent Judges issued 42 search warrant against the Petitioner and the corporation, directing peace officers to search the persons and/or premises of their offices, warehouses, residences and to seize and take possession of personal properties. ● Personal properties to be seize are described as follows: Books of accounts, financial records, vouchers, correspondence, receipts, ledgers, journals, portfolios, credit journals, typewriters, and other documents and/or papers showing allbusiness transactions including disbursements receipts, balance sheets and profit and loss statements and Bobbins. These are considered subject of the offense of violation of Central Bank Laws, Tariff and Customs Laws, Internal Revenue Code and Revised Penal Code. ● Petitioner filed with the SC an original action for certiorati, prohibition, mandamus and injunction, and prayed that writ of preliminary injunction be issued pending the final disposition of the case. ● March 1962, Court issues writ of preliminary injunction; June 1962, the writ was partially lifted insofar as the personal property seized from the office of the corporations are concerned but maintained as regards those personal properties seized in the residences of the petitioners. Contentions Petitioner Respondent Alleged that the search warrants are null and void Alleged that the following: because: 1. search warrants were valid and 1. does not describe with particularity the issued in accordance with law documents, books and things to be seized 2. defects of the said warrant 2. cash money, not mentioned in the warrants, were cured by petitioner’sconsent were seized 3. effects seized are admissible in 3. warrants were issued to fish evidence evidence against petitioner, 4. searches and seizure were made in an illegal regardless of the alleged illegality manner of the warrants. 5. personal properties seized were not delivered to the courts that issued warrants Lower Courts Appellate Court Issue W/N the petitioners are the proper party in alleging the invalidity of the documents, papers, and other things found and seized in the offices of the corporations. SC Ruling We hold that petitioners herein have no cause of action to assail the legality of the contested warrants and of the seizures made in pursuance thereof, for the simple reason that said corporations have their respective personalities, separate and distinct from the personality of herein petitioners, regardless of the amount of shares of stock or of the interest of each of them in said corporations, and whatever the offices they hold therein may be. Indeed, it is well settled that the legality of a seizure can be contested only by the party whose rights have been impaired thereby, and that the objection to an unlawful search and seizure is purely personal and cannot be availed of by third parties. Consequently, petitioners herein may not validly object to the use in evidence against them of the documents, papers and things seized from the offices and premises of the corporations adverted to above, since 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.
Indeed, it has been held:
. . . that the Government's action in gaining possession of papers belonging to the corporation did not relate to nor did it affect the personal defendants. If these papers were unlawfully seized and thereby the constitutional rights of or any one were invaded, they were the rights of the corporation and not the rights of the other defendants. Next, it is clear that a question of the lawfulness of a seizure can be raised only by one whose rights have been invaded . Certainly, such a seizure, if unlawful, could not affect the constitutional rights of defendants whose property had not been seized or the privacy of whose homes had not been disturbed ; nor could they claim for themselves the benefits of the Fourth Amendment, when its violation, if any, was with reference to the rights of another. Remus vs. United States (C.C.A.)291 F. 501, 511. It follows, therefore, that the question of the admissibility of the evidence based on an alleged unlawful search and seizure does not extend to the personal defendants but embraces only the corporation whose property was taken. . . . (A Guckenheimer & Bros. Co. vs. United States, [1925] 3 F. 2d. 786, 789, Emphasis supplied.)