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In

People v. de Gracia, 233 SCRA 716, the raid of, and the consequent seizure of
firearms and ammunition in, the Eurocar Sales Office at the height of the
December 1989 coup detat was held valid, considering the exigent and
emergency situation obtaining. The military operatives had reasonable ground to
believe that a crime was being committed, and they had no opportunity to apply
for a search warrant from the courts because the latter were closed. Under such
urgency and exigency, a search warrant could be validly dispensed with.

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