Case Digest (G.R. No. L-20387) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jesus P. Morfe vs. Amelito R. Mutuc (G.R. No. L-20387, January 31, 1968), Judge Jesus P. Morfe of Pangasinan filed a declaratory relief action on January 31, 1962 against Executive Secretary Amelito R. Mutuc and the Secretary of Justice. He challenged Section 7 of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act of 1960), which required every public officer to file a sworn statement of assets and liabilities within thirty (30) days after assumption of office and “within the month of January of every other year thereafter.” Morfe had complied with his initial filing but refused further biennial submissions, alleging that the periodic requirement was an oppressive exercise of police power, violated the due process clause and invaded his right to privacy under the prohibition on unreasonable search and seizure and the privilege against self-incrimination. The Court of First Instance of Pangasinan, deciding on the pleadings, declared the periodic-filing provision u Case Digest (G.R. No. L-20387) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- Jesus P. Morfe, a judge of a Court of First Instance, filed a declaratory relief action on January 31, 1962, against Amelito R. Mutuc as Executive Secretary, et al., challenging the constitutionality of Republic Act No. 3019, Section 7.
- The provision required every public officer, within thirty days after assuming office and “within the month of January of every other year thereafter,” to file a sworn statement of assets and liabilities, income sources, personal and family expenses, and taxes paid.
- Procedural History
- Morfe prepared and filed the initial statement upon assumption of office but refused to file the biennial statement, alleging violations of due process, privacy rights, protection against unreasonable searches and seizures, and the privilege against self-incrimination.
- The Court of First Instance of Pangasinan, deciding on the pleadings alone, declared Section 7 unconstitutional on July 19, 1962, for exceeding the police power and infringing fundamental rights.
- Defendants appealed, invoking the presumption of constitutionality, the legitimacy of police-power regulations to curb corruption, and denial of any rights infringement.
Issues:
- Does the biennial filing requirement under Section 7 of RA 3019 violate the due process clause by constituting an oppressive exercise of the police power or an unreasonable invasion of liberty?
- Does the requirement infringe the constitutional right to privacy, the prohibition against unreasonable searches and seizures, or the privilege against self-incrimination?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)