Facts:
This case involved Dr. Nemesio E. Prudente, who petitioned against the orders of Judge Abelardo M. Dayrit of the RTC Manila, Branch 33, which denied Prudente’s motion to quash Search Warrant No. 87-14. The search warrant was applied for by P/Major Alladin Dimagmaliw of the Western Police District’s Intelligence Special Action Division, alleging illegal possession of firearms and explosives by Prudente, kept within the Polytechnic University of the Philippines (PUP) premises. The application based its allegations on hearsay—from “information verified from verified sources” and not on direct knowledge. Despite these bases, the search warrant was issued, leading to a search that found three live fragmentation hand grenades in Prudente’s office washroom. Prudente moved to quash the warrant, arguing lack of personal knowledge by witnesses, lack of specificity in describing the place to be searched, generality of the warrant, and failure to comply with Supreme Court Circular No. 19. His motions were denied, prompting the petition for certiorari.
Issues:
1. Whether the search warrant application met the requirement of probable cause based on personal knowledge.
2. Whether the search warrant sufficiently described the place to be searched.
3. Whether the search warrant was issued in connection with one specific offense.
4. Whether the issuance violated Supreme Court Circular No. 19 regarding the urgency of application outside normal court hours.
Court’s Decision:
The Supreme Court granted Prudente’s petition, annulling and setting aside the warrant and orders. The Court found the warrant invalid due to:
– Lack of probable cause based on personal knowledge, as both the application and supporting deposition were based on hearsay.
– Insufficiently detailed examination of witnesses by the judge, lacking in searching questions and answers.
– The description of the place to be searched was deemed sufficiently specific, but this point was moot given the warrant’s other flaws.
– The warrant’s supposed violation of specifying only one specific offense was dismissed, as the Court found it was issued for a specific category of offense under PD No. 1866.
– The non-compliance with Circular No. 19 was deemed not to affect the warrant’s validity, though this point was moot given the finding of other substantial flaws.
Doctrine:
The Supreme Court reiterated stringent requirements for the valid issuance of a search warrant, emphasizing the necessity of basing probable cause on facts within the personal knowledge of the complainant or witnesses. The decision reinforced the mandatory nature of examining complainant and witnesses through detailed searching questions and answers, underscoring the importance of protecting constitutional rights against unreasonable searches and seizures.
Class Notes:
– Probable cause for a search warrant must be based on direct knowledge, not hearsay.
– Search warrants must particularly describe the place to be searched.
– A valid search warrant must be connected to a specific offense.
– Compliance with procedural rules, such as the urgency of application for search warrants, is crucial but was considered less significant in this case due to other overriding flaws.
– Protecting constitutional rights against unreasonable search and seizure demands strict adherence to legal requirements for search warrants.
Historical Background:
The context of this case reflects the tension between state security measures and individual rights during a period in the Philippines marked by political instability and efforts to curb illegal possession of firearms and explosives. The stringent review by the Supreme Court of the search warrant’s validity underscores the judiciary’s role in balancing the need for law enforcement with the protection of constitutional rights, emphasizing procedural correctness and the foundations of probable cause in issuing search warrants.
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