In the realm of Philippine remedial law, the Scatter Shot Doctrine serves as a critical safeguard for the constitutional right against unreasonable searches and seizures. It is a principle that invalidates search warrants that are overly broad or issued for multiple, unrelated offenses, effectively preventing the state from engaging in "fishing expeditions" against its citizens.

I. Definition and Conceptual Core

The Scatter Shot Doctrine dictates that a search warrant must be issued for one specific offense only. When a single warrant covers several unrelated crimes or a broad category of prohibited acts without pinpointing a particular violation, it is disparagingly referred to as a "scatter shot" warrant.

Under Philippine law, such a warrant is considered a general warrant, which is constitutionally abhorrent. The doctrine ensures that the issuing judge has conducted a focused examination of the existence of probable cause for a specific crime, rather than granting the police a "blank check" to search for evidence of any possible illegality.

II. Constitutional and Statutory Basis

The doctrine is rooted in Article III, Section 2 of the 1987 Philippine Constitution, which states:

"The right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures of whatever nature and for any purpose shall be inviolable, and no search warrant or warrant of arrest shall issue except upon probable cause to be determined personally by the judge... and particularly describing the place to be searched and the persons or things to be seized."

This is further reinforced by Rule 126, Section 4 of the Revised Rules of Criminal Procedure, which explicitly mandates:

A search warrant shall not issue except upon probable cause in connection with one specific offense.

III. The "One Specific Offense" Rule

The primary test for whether a warrant violates the Scatter Shot Doctrine is the unity of the offense.

Multiple Violations: If a warrant is issued for "Violation of R.A. 9165 (Drugs) and R.A. 10591 (Firearms)," it is a classic scatter shot warrant. These are distinct crimes requiring different sets of evidence and elements.
Broad Categorization: A warrant issued for "Illegal Possession of Firearm and Ammunition" is generally acceptable because the ammunition is incidental to the firearm. However, a warrant issued for "violations of the Revised Penal Code" would be void for being a scatter shot.
The Harm Prevented: Without this rule, law enforcement could use a minor infraction as a pretext to search for evidence of much larger, unrelated crimes, bypassing the requirement to show probable cause for those specific larger crimes.

IV. Distinction: Particularity of Description vs. Scatter Shot

It is vital to distinguish between two different grounds for quashing a warrant:

Particularity of Description: Focuses on what is being seized and where. A warrant might be for one offense (e.g., Theft) but fail because it says "search the house for stolen items" without describing the items.
Scatter Shot Doctrine: Focuses on the legal basis of the warrant. Even if the items are described perfectly, if the warrant lists three different crimes as the reason for the search, it falls under the Scatter Shot Doctrine.

V. Legal Consequences of a Scatter Shot Warrant

A warrant found to be "scatter shot" is void ab initio (void from the beginning). This leads to several procedural and substantive outcomes:

Motion to Quash: The respondent may file a motion to quash the warrant before the court that issued it.
The Exclusionary Rule: Under the "Fruit of the Poisonous Tree" doctrine, any evidence seized under a scatter shot warrant is inadmissible in evidence for any purpose in any proceeding.
Civil and Administrative Liability: Officers implementing a patently void warrant may be held liable for damages or administrative sanctions.

VI. Evolution and Modern Application

In early jurisprudence, such as Stonehill v. Diokno (1967), the Supreme Court struck down warrants issued for "violation of Central Bank Laws, Tariff and Customs Laws, the Internal Revenue Code and the Revised Penal Code." The Court noted that such warrants made it impossible to determine if probable cause existed because the offenses were so diverse.

In modern practice, the Court has remained strict. While law enforcement often argues for "substantial compliance," the judiciary maintains that the one-offense rule is a mandatory prerequisite for the validity of the warrant. If multiple crimes are suspected, the proper procedure is for the authorities to apply for separate warrants, each supported by its own set of affidavits and evidence establishing probable cause for that specific crime.

Summary Table: Validity of Search Warrants

Feature	Requirement	Scatter Shot Violation
Number of Offenses	Exactly one	Two or more unrelated offenses
Probable Cause	Tied to the specific offense	General suspicion of wrongdoing
Description	Particular and limited	Broad or "general"
Legal Status	Valid and enforceable	Void; Evidence is suppressed