PEOPLE v.

MARTI
G.R. No. 81561
Jan. 18, 1991
BIDIN, J.
Facts:
Andre Marti and Shirley Reyes went to Anita Reyes to have four
packages sent to Switzerland. Anita and her husband later opened all
parcels to check contents in pursuance of standard operating
procedure. It was then that they noticed that the articles emanated a
funky smell, and notified the police of the same. The packages were
found to have contained marijuana in various forms, and on the basis
of such Marti was prosecuted accordingly.
Issue:
Whether there was a violation of Martis right against
unreasonable searches and siezures.
Ruling:
NO. The Bill of Rights embodied in the Constitution is not meant
to be invoked against the acts of private individuals, it is directed only
against the government and its agencies tasked with the enforcement
of the law. Since the discovery was ultimately due to the acts of private
individuals Anita Reyes and husband, there was not even a search as
the articles were in plain view.
STONEHILL v. DIOKNO
No. L-19550
June 19, 1967
CONCEPCION, C.J.
Facts:
Respondent judges issued a number of warrants against several
corporations, ordering the search and the seizure of a number of items
relating to their business transactions. Petitioners in the case question
the validity of the Search Warrants particularly due to the fact that
private residences of several officers of the said corporations were
raided as well.
Issues:
Whether all the issued warrants were valid
Whether all the parties in question had standing to question the
validity of the warrants.
Ruling:
NO. Some of the warrants in questions partook in the nature of
general warrants which are outlawed for failing to adhere to
Constitutional requirements such as particularity and on specific
offenses. They are outlawed as they pose a danger to the sanctity of a

persons residence. Furthermore, the enforcers erred in searching the

residences of private individuals who happen to be employed by the
corporation.
NO. Some parties had no standing to question the service of the
warrants in the corporate offices, since they were suing in their private
capacity. The objection to an unlawful search is purely personal and
cannot be availed of by third parties.
BURGOS, SR. v. CHIEF OF STAFF, AFP
No. L-64261
Dec. 26, 1984
ESCOLIN, J.
Facts:
Search Warrants were issued against the newspaper publishing
companies Metropolitan Mail and We Forum and subsequently
served through the military, with papers, publishing machinery, and
other related business documents being seized. Years later, after
appealing to Executive Clemency, petitioners sought recourse with the
courts questioning the validity of the warrants. In particular, the
service of one of the warrants was questioned since it was directed
against Burgos, Sr. but property belonging to Burgos, Jr. was seized as
well. Also, the question on probable cause was raised.
Issue:
Whether ownership of property is if any consequence in searches
and seizures.
Whether there was probable cause to warrant the issuance of the
warrants.
Ruling:
NO. Ownership is of no consequence, and it is sufficient that the
person against whom the warrant is directed has control or possession
of the property sought to be seized.
NO. Probable cause is defined as such facts and circumstances as
would lead a reasonable discreet and prudent man to believe that an
offense has been committed and that the objects sought in connection
with the offense are in the place sought to be searched. A person
wearing to or supporting the application for the search warrants must
know personally the facts. The warrants in question hardly satisfy the
constitutional prerequisite of probable cause.
TAMBASEN v. PEOPLE
G.R. 89103
Jul. 14, 1995
QUIASON, J.

Facts:
P/Sgt. Natuel applied for a search warrant alleging he received
information that several guns, explosives, and subversive documents
were in possession of Leon Tambasen. The warrant was granted and
served, and radio equipment as well as cash was confiscated from
Leon Tambasen. Tambasen requested the return of the same as they
were not in anyway related to the items alleged, particularly the cash
amounting to 14,000php. The MTC granted the same, and questioned
the confiscation of the cash. Now, the Solicitor General questions the
ruling of the MTC.
Issue:
Whether the warrant issued against Leon Tambasen was valid.
Ruling:
NO. For one, the police acted beyond the parameters of their
authority when they seized items which were not in relation with the
crime charged. But more importantly, the warrant partook in the
nature of a scatter-shot warrant, which charged more than one
offence.
PLACER v. VILLANUEVA
G.R. Nos. 60349-62
Dec. 29, 1983
ESCOLIN, J.
Facts: