Facts
In 1960, the Anti-Graft and Corrupt Practices Act was enacted by the Congress of the Philippines to deter public officials and employees from committing acts of dishonesty and improve the morality in public service.
One of its provisions requires every public officer to prepare and file a true detailed and sworn statement of assets and liabilities, including a statement of the amounts and sources of income, personal and family expenses, and income taxes paid for the next preceding calendar within 30 days after approval or assumption of office, within the month of January of every other year thereafter, and upon termination of the position.
Such provision was declared unconstitutional, null and void by the lower court from whose decision this appeal rose from.
Issue
Whether the periodical submission requirement of a sworn statement of assets and liabilities by public officers violates due process and the constitutional right to privacy.
Ruling
The lower court sustained the plaintiff’s claim that the periodical submission requirement exceeds the permissible limit of police power and is thus offensive to the due process clause. However, the Supreme Court of the Philippines reversed the decision, ruling that the requirement of periodical submission of a sworn statement of assets and liabilities is a valid exercise of police power and does not constitute an unreasonable search and seizure or a violation of the right to privacy. The Court explained that the submission of the statement is not compulsory but rather voluntary, and the purpose of the requirement is to promote transparency and accountability in public service, prevent corruption, and maintain the public’s trust and confidence in the government. The Court also pointed out that public officers are accountable to the people and must subject themselves to reasonable regulation and scrutiny. Thus, the Court declared the provision constitutional and dismissed the plaintiff’s claim for declaratory relief.
Ratio
The Court held that the periodical submission requirement of a sworn statement of assets and liabilities by public officers is a valid exercise of police power and does not violate due process or the right to privacy. The submission of the statement is voluntary and serves the legitimate purpose of promoting transparency, accountability, and public trust in government. Public officers must subject themselves to reasonable regulation and scrutiny in the performance of their public duties, and the requirement is not oppressive but rather a reasonable means of achieving a legitimate end.
Disposition
The Supreme Court reversed the decision of the lower court and declared the periodical submission requirement of a sworn statement of assets and liabilities by public officers constitutional. The plaintiff’s claim for declaratory relief was dismissed.