In Zulueta vs. CA ( Feb.

1986) it was held that pictures and love letters

proving the infidelity of the husband, kept by him in his private clinic,
taken by the wife without the knowledge of the husband, are inadmissible as
evidence

for

being

obtained

in

violation

of

the

husbands

privacy

of

communication and correspondence.

The intimacies between husband and wife do not justify anyone of them
breaking the drawers and cabinet of the other and ransacking them for any
telltale evidence of marital infidelity. A person, by contracting marriage,
does not shed his or her integrity or his right to privacy as an individual
and the constitutional protection is available to him or her

In Deano v. Godinez, 12 SCRA 483, it was held that a report sent by a public official to
his superior is privileged communication, because its submission is pursuant to the
performance of a legal duty.
Besides, in sending his report, the Secretary of Public Works acted in the discharge of
his official duties. Hence, he was acting in behalf of the Republic of the Philippines and
within the scope of his authority According to the ruling in Sanders v. Veridiano, 162
SCRA 88, a suit brought against a public official for writing a letter which is alleged to be
libelous but which was written while he was acting as agent of the government and
within the scope of his authority is actually a suit against the State without its consent.

The court built upon the exclusionary rule and other evidence rules in the case of Silverthorne
Lumber Co. v. U.S. The case tool place in 1918 with the Silverthorne Lumber Company, run by
Fredrick Silverthorne and his sons, being accused of avoiding payment of federal taxes. They were
then asked to turn over their accounting books but instead declined to do so under the Fifth
Amendment protection against self incrimination. Federal agents then raided the company without a
warrant and took the evidence they needed. Upon appeal, the books were ordered to be returned
under the Fourth Amendment and the exclusionary rule against illegal search and seizure. The trial
continued, and despite the setback of returning the evidence photocopies of the accounting books
were admitted into evidence at court. The Silverthorne's were convicted using the copies as evidence.

The Silverthorne's appealed the conviction, which rose through the judiciary system eventually
reaching the Supreme Court. The court ruled that just as illegally seized evidence cannot be used at
trial, neither can evidence be admitted to court that derives from an illegal seizure. The conviction of
the Silverthorne's was overturned and they were released as free men. This case formed the
precedent of what is now known as the fruit of the poisoned tree doctrine.