Myla Ruth N.

Sara

Pangandaman v. Casar

Facts:

The case originated in Lanao. The offended party was ambushed in Lanao, but he
survived. Based on his description, there were around 50 persons who staged the
ambush from both sides of the hill. However, he could not recognize anyone of the
50. But he filed a case against all 50 ambushers, all “JOHN DOES”. So the court
issued a warrant of arrest against the 50 John Does.

Issue: W/N the warrant of arrest is valid? Can a court issue a warrant of arrest
against an unknown accused?

Held:
NO it is not valid. It is of the nature of a general warrant, one of a call of writs long
prescribed as unconstitutional and once anathematized as totally subversive of
the liberty of the subject. Clearly violative of the constitutional injunction that
warrants of arrest should particularly describe the person or persons to be seized.
The warrant as against unidentified subjects will be considered as null and void.