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SILAHIS INTERNATIONAL HOTEL v. ROGELIO S. SOLUTA

FACTS:

This case involves a Petition for Review on Certiorari that challenges the Court of Appeals Decision holding the petitioners Silahis International Hotel, Inc. and Jose Marcel Panlilio, along with Floro Maniego and Steve Villanueva, civilly liable for damages for violating the respondents' constitutional right against unreasonable search of their office. Jose Marcel Panlilio was the Vice President for Finance of Silahis International Hotel, Inc., while the respondents were employees of the hotel and officers of the Glowhrain-Silahis Union Chapter, the hotel employees union.

Floro Maniego, the General Manager of the security agency contracted by the hotel, received reports of illegal activities in the union office. With Panlilio's approval, Maniego conducted surveillance of suspected union members. On January 11, 1988, Panlilio, accompanied by his personal secretary, a reporter, and security guards, entered the union office with permission. They conducted a search and found marijuana. Panlilio reported the matter to the authorities.

The respondents, however, claim a different version of events. According to them, on the same day, a laundrywoman heard pounding sounds and saw five men forcibly opening the door of the union office. She later heard the door being opened again after she closed it. Union officer Soluta filed a complaint and attempted to open the door with a locksmith, but they were attacked by the men. They sought police assistance, and Panlilio and his companions arrived. Despite objections, Panlilio ordered the forced opening of the door, leading to the discovery of marijuana.

As a result of the discovery, a case for violation of the Dangerous Drugs Act was filed against the union officers, but they were eventually acquitted by the Regional Trial Court. The union officers and the union then filed a complaint against the petitioners for malicious prosecution and violation of their constitutional right against an illegal search. The Manila RTC held the petitioners, the hotel, Panlilio, Maniego, and Villanueva, civilly liable for damages, which was affirmed by the Court of Appeals with modifications.

ISSUES:

  1. Whether petitioners are liable for damages under Article 32 of the Civil Code.

  2. Whether the search conducted by petitioners was reasonable under the circumstances.

  3. Whether there was a violation of the right against unreasonable search and seizure

  4. Whether the petitioners are liable for damages for the violation of constitutional rights

RULING:

  1. Yes, petitioners are liable for damages under Article 32 of the Civil Code. Article 32 provides that any public officer or employee, or any private individual, who obstructs or violates another person's rights, including the right to be secure against unreasonable searches and seizures, shall be liable for damages. The Constitutional protection against illegal searches and seizures applies not only to public officers but also to private individuals. It is not necessary for the defendant to have acted with malice or bad faith for liability to arise.

  2. No, the search conducted by petitioners was not reasonable under the circumstances. Despite receiving reports of illegal activities in the union office, petitioners conducted a warrantless search without a valid reason, without obtaining a search warrant, and despite the objection of one of the union officers. This act constituted a violation of the individual respondents' constitutional right against unreasonable search and provides the basis for the award of damages.

  3. The Court upheld the grant of damages by the trial court for violation of the right against unreasonable search and seizure. The raiding party did not apply for a judicial warrant despite having sufficient time to do so, and they went on with the raid and seized the goods of the private respondents.

  4. The petitioners, together with the individuals who orchestrated the illegal search, are jointly and severally liable for actual, moral, and exemplary damages to the individual respondents. This is in accordance with Article 32 of the Civil Code, which holds responsible any person directly or indirectly responsible for the violation of constitutional rights and liberties of another.

PRINCIPLES:

  • Violation of constitutional rights, whether constituting a penal offense or not, must be guarded against and can lead to civil liability.

  • Public officers and private individuals can be held civilly liable for violations of rights enumerated in Article 32 of the Civil Code.

  • It is not necessary for the defendant to have acted with malice or bad faith for liability under Article 32 to arise.

  • The Constitutional protection against illegal searches and seizures applies to both public officers and private individuals.

  • A warrantless search is not allowed unless it falls under one of the exceptional instances recognized by law.

  • The right against unreasonable searches and seizures is a personal right that may be waived expressly or impliedly, but a waiver by implication cannot be presumed. Clear and convincing evidence of an actual intention to relinquish the right is required for a valid waiver.

  • A violation of the right against illegal search and seizure can be a basis for the recovery of damages under Article 32 of the Civil Code.

  • The person indirectly responsible for the violation of constitutional rights can also be held liable for damages or injury caused to the aggrieved party.

  • Private individuals can be held liable for damages for the violation of constitutional rights under Article 32 of the Civil Code.