The warrant must contain specific and detailed information about the

place to be searched and the items to be seized in order to avoid general

or exploratory searches. A search warrant must particularly describe the
place to be searched and the things to be seized with sufficient detail to
enable the officer serving the warrant to identify the property authorized
to be seized.

Jaylord Dimal vs. People of the Philippines

G.R. No. 216922, PERALTA, April 18, 2018

Facts:
A petition for review on certiorari to reverse the CA decision related to
orders in Criminal Case Nos. Q-12-175369 to Q-12-175371, denying the
Omnibus Motion to quash a search warrant in kidnapping and multiple
murder case against Jaylord A. Dimal and others. On September 6,
2010, Lucio Pua, Rosemarie Pua, and Gemma Eugenio were scheduled
to visit Jaylord A. Dimal's compound. After being reported missing, a
search was conducted; subsequent investigations implicated Dimal and
others in the alleged murders.

An application for a search warrant was filed, leading to the issuance of

Search Warrant No. 10-11 for Dimal's premises, seeking specific items
related to the crime. Petitioners objected to the search warrant, arguing
its lack of particularity and objecting to the seizure of items not directly
related to the crime.

Issue/s:
The application of the omnibus motion rule to the motion to quash
search warrants.

The particularity of the description of the items to be seized in the search

warrant.
The admissibility of items seized under the "plain view doctrine" which
were not described in the search warrant.

Held:
The petition for review on certiorari was partly granted. The CA
decision was affirmed with modification, specifically declaring several
properties seized under Search Warrant No. 10-11 inadmissible in
evidence, as they were neither particularly described in the search
warrant nor seized under the "plain view doctrine". The court sustained
the validity of Search Warrant No. 10-11 and the admissibility of items
particularly described in the warrant, but objects not specified in the
search warrant were ordered to be restored to the person from whom
they were unlawfully seized.

WHEREFORE, premises considered, the petition for review on certiorari

is PARTLY GRANTED. The Court of Appeals Decision dated August 27,
2014 in CA-G.R. SP No. 128355 is AFFIRMED with MODIFICATION
to declare that the following properties seized under Search Warrant No.
10-11 are inadmissible in evidence for neither having been particularly
described in the search warrant nor seized under the "plain view
doctrine":

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