Case Digest (G.R. No. L-1716)
Facts:
Material Distributors (Phil.), Inc., and Harry Lyons, Petitioners, vs. Felipe Natividad, Judge of First Instance of Manila, and Lope Sarreal, Respondents, G.R. No. L-1716, June 28, 1949, the Supreme Court En Banc, Perfecto, J., writing for the Court.
On March 24, 1947, Lope Sarreal filed a complaint (amended April 10, 1947, to include Harry Lyons) seeking money judgments totalling P1,256,229.30 against Material Distributors (Phil.), Inc. and Lyons. On May 27, 1947, Sarreal moved for production and inspection of specified books, ledgers, letters and cablegrams of Material Distributors (Phil.), Inc. and of Harry Lyons; on June 4, 1947, he filed a supplemental motion seeking production of the originals of Annexes A and B to the complaint.
On July 16, 1947, the respondent judge (Judge Felipe Natividad) granted Sarreal’s motions and ordered production of the listed documents for inspection on July 24, 1947. Because Lyons was absent from the Philippines, petitioners obtained a postponement to August 15, 1947, and then on August 13, 1947, filed a motion for reconsideration arguing (inter alia) that Article 46 of the Code of Commerce and the constitutional right to inviolability of correspondence prohibited the order, that production would be a forbidden “fishing expedition” under Rule 21, and that production might violate the privilege against self-incrimination. The trial judge denied reconsideration on September 27, 1947.
Petitioners brought the present action to impugn the July 16 and September 27, 1947 orders as issued in excess of jurisdiction or with grave abuse of discretion and prayed for their annulment or modification. Respondent Sarreal answered, defending the orders by arguing (among other points) that the motions showed adequate “good cause” under Rule 21, Section 1, that Article 46 did not prevent production where the documents belong to a party to the action, that the constitutional privacy guarantees permit disclosure upon lawful court order, and tha...(Subscriber-Only)
Issues:
- Did the trial judge exceed his jurisdiction or commit grave abuse of discretion in ordering production and inspection of the documents (orders of July 16 and September 27, 1947)?
- Did Sarreal’s original and supplemental motions show “good cause” under Rule 21, Section 1 to justify the production and inspection order?
- Did the orders violate petitioners’ constitutional privilege against self-incrimination?
- Did the orders infringe the constitutional inviolability of correspondence or amount to an unreasonable search and seizure prohibited by the Constitution?
- Were the motio...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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