Case Digest (G.R. No. L-20387)
Facts:
Jesus P. Morfe v. Amelito R. Mutuc, as Executive Secretary, et al., G.R. No. L-20387, January 31, 1968, the Supreme Court En Banc, Fernando, J., writing for the Court.
Plaintiff-appellee Jesus P. Morfe, then a judge of a Court of First Instance, filed a declaratory relief action in the Court of First Instance of Pangasinan on January 31, 1962, challenging the constitutionality of the portion of Section 7 of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act, approved August 17, 1960) that required every public officer to file a sworn statement of assets and liabilities "within the month of January of every other year thereafter" after an initial filing upon assumption of office. Morfe conceded he had filed the initial statement but contended that the periodical filing requirement was an oppressive exercise of police power and an unlawful invasion of rights to due process, privacy (as implicit in the prohibitions against unreasonable search and seizure), and against self-incrimination.
Defendants-appellants, including the Executive Secretary and the Secretary of Justice, answered and denied the constitutional objections, asserting among other defenses that a public officer voluntarily assumes the obligation to disclose personal affairs while holding public trust and that the statute was a reasonable exercise of the police power to promote honest and clean public service. The lower court took the case as submitted on the pleadings and issued judgment on July 19, 1962, declaring Section 7 unconstitutional "insofar as it required periodical submittal" of the sworn statements after an initial filing.
The government appealed the lower court's judgment to the Supreme Court. The Supreme Court reviewed the pleadings, the statute and releva...(Subscriber-Only)
Issues:
- Did the lower court err in declaring Section 7 of R.A. No. 3019 unconstitutional where there was no factual foundation presented to overcome the presumption of constitutionality?
- Is the statutory requirement of periodical submission of sworn statements of assets and liabilities a valid exercise of the police power, or does it violate the due process guarantee (liberty)?
- Does the periodical filing requirement unconstitutionally invade the right to privacy?
- Does the requirement contravene the guarantees against unreasonable search and seizure and against self-incrimination?
- May the provision be invalidated merely as an affront to personal int...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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