Title
Morfe vs. Mutuc
Case
G.R. No. L-20387
Decision Date
Jan 31, 1968
A judge challenged the constitutionality of requiring public officials to file periodic sworn statements of assets and liabilities, arguing it violated privacy and due process. The Supreme Court upheld the law, ruling it a valid exercise of police power to ensure transparency and prevent corruption.

Case Digest (G.R. No. L-20387)
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)

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