G.R. No. L-37884 November 14, 1975
VICENTE B. CHUIDIAN, petitioner, vs. THE HONORABLE RICARDO C. PUNO, ENRIQUE RAZON, E. RAZON, INC., GERONIMO VELASCO, FRANCIS DE BORJA, JOSE FRANCISCO, ALFREDO DE LEON, JR., GABRIEL LLAMAS and LUISA M. DE RAZON, respondents.

FACTS

Petitioner Vicente B. Chuidian filed a civil case against private respondents, including Enrique Razon and E. Razon, Inc., seeking the turnover of shares of stock, damages, and an accounting of corporate management. During the pendency of this case, petitioner filed a motion for inspection, photographing, and copying of various corporate documents (e.g., financial statements, books of account, customs reports) from 1966 to 1973 under Rule 27 of the Rules of Court. He alleged these documents were necessary to prove his claims that respondents had submitted conflicting financial statements to government agencies and had failed to declare substantial corporate income, potentially amounting to mismanagement and misappropriation.
The respondent judge denied the motion. The denial was based on the ground that the inquiry into the facts sought from the documents was prohibited, as the documents were deemed absolutely privileged under Presidential Decree No. 23, as amended by Presidential Decree No. 161 (the Tax Amnesty Decree). Respondents E. Razon, Inc. and Enrique Razon had availed themselves of the tax amnesty by filing declarations and paying the corresponding taxes. The court held that the decrees forbade any examination or inquiry into such declarations and related documents.

ISSUE

Whether the respondent judge acted with grave abuse of discretion in denying the petitioner’s motion for inspection of documents based on the absolute privilege and confidentiality granted by the Tax Amnesty Decrees.

RULING

The Supreme Court upheld the denial, finding no grave abuse of discretion. The legal logic centers on the explicit and sweeping confidentiality mandate of Presidential Decree No. 23, as amended. The decree provides that any declaration filed pursuant to it “shall be deemed absolutely privileged,” and no person or government official may “examine, inquire or look into” such a declaration. Violation is penalized. The Court emphasized that the presidential intent was to grant complete inviolability to encourage full disclosure of previously hidden income. This confidentiality shield extends beyond mere protection from criminal or tax liability to the government.
The Court reasoned that allowing the inspection sought by the petitioner would constitute a prohibited “inquiry” into the very income covered by the amnesty declaration. The documents requested (financial statements, books of account, customs reports) were directly relevant to the declared income. Permitting such discovery in a civil suit would undermine the decree’s objective, as taxpayers might refrain from availing of the amnesty if their disclosures could later be used against them in private litigation. The privilege is not limited to protecting against government action but includes protection from private inquiries that could lead to civil liability. The Court concluded that the respondent judge correctly applied the law. The dismissal of the petition does not deprive the petitioner of proving his case; he must simply do so using other competent evidence not covered by the absolute privilege.