### Facts:
The case revolves around the issuance and implementation of Search Warrant No. 799 (95) by the Regional Trial Court (RTC), Branch 104, Quezon City, targeting the premises of Paper Industries Corporation of the Philippines (PICOP) in Bislig, Surigao del Sur, for the possession of unlicensed firearms and ammunition. The petitioners, comprising PICOP and several of its officers and employees, sought to nullify the search warrant, arguing that it was obtained and executed in violation of their constitutional rights against unreasonable searches and seizures.
On January 25, 1995, Police Chief Inspector Napoleon B. Pascua applied for the search warrant at the RTC of Quezon City, presenting the joint deposition of SPO3 Cicero S. Bacolod and SPO2 Cecilio T. Morito, along with supplementary statements from two other individuals. After a hearing, where only SPO3 Bacolod was examined, the search warrant was issued by Judge Maximiano C. Asuncion. On February 4, 1995, the warrant was executed within the expansive PICOP compound, resulting in the seizure of numerous firearms and ammunition.
The petitioners challenged the warrant at the RTC, arguing its invalidity and the unreasonableness of the search. Two Orders issued by the RTC, dated March 23, 1995, and August 3, 1995, denied the motions to quash the search warrant and to suppress the evidence gathered. Subsequently, the petitioners elevated the matter to the Supreme Court on questions of law.
### Issues:
1. Whether the search warrant was issued in violation of the constitutional and procedural requirements concerning probable cause and the manner of its determination.
2. Whether the search warrant failed to specifically describe the place to be searched, thereby making it a general warrant.
3. Whether the evidence obtained through the execution of the search warrant was admissible.
### Court’s Decision:
The Supreme Court granted the petition, declaring Search Warrant No. 799 (95) null and void for the following reasons:
1. **Personal Examination by Judge**: The trial judge failed to personally examine the applicant and his witnesses in accordance with constitutional and statutory requirements. The examination of only SPO3 Bacolod did not suffice, primarily because the other witnesses, including the applicant, were not examined at all.
2. **Witness’s Personal Knowledge**: SPO3 Bacolod did not have personal knowledge that the petitioners were unlicensed to possess the enumerated firearms and explosives. His testimony was based on belief rather than factual knowledge, making it insufficient to establish probable cause.
3. **Particularity of the Place to be Searched**: The search warrant did not describe with particularity the place to be searched within the vast PICOP compound, essentially granting the officers unrestricted authority to search any of the numerous facilities therein, contrary to constitutional mandates.
Consequently, all evidence seized under the warrant was deemed inadmissible in any proceeding, adhering to the principle that evidence obtained in violation of constitutional rights is “fruit of the poisonous tree”.
### Doctrine:
This case reiterates the strict requirements for the issuance of a valid search warrant: (1) probable cause determined personally by the judge; (2) examination under oath of the complainant and the witnesses he may produce; (3) the warrant must particularly describe the place to be searched and the items to be seized; and (4) reliance on factual, personal knowledge rather than beliefs or hearsay.
### Class Notes:
– **Probable Cause**: Determined personally by the judge through examination under oath of the complainant and witnesses.
– **Personal Knowledge**: Witnesses must testify on matters based on their personal knowledge, not mere beliefs or hearsay.
– **Specificity Requirement**: A search warrant must particularly describe the place to be searched and the items to be seized, preventing broad or general searches.
– **Evidence Admissibility**: Evidence obtained through an unconstitutional search warrant is inadmissible in any proceeding (“fruit of the poisonous tree” doctrine).
### Historical Background:
This case underscores the judicial scrutiny required in the issuance and execution of search warrants within the constitutional framework of the Philippines, emphasizing the protection against unreasonable searches and seizures amidst governmental efforts to maintain law and order.
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