Gregorio Perfecto
Encyclopedia
Gregorio Perfecto was a Filipino
journalist
, politician
and jurist
who served as an Associate Justice
of the Supreme Court of the Philippines
from 1945 to 1949. A controversial figure who was described as an “apostle of liberal causes”, Perfecto was notable for his libertarian
views, his colorful writing style, and the frequency of his dissenting opinion
s while on the Supreme Court.
. When he was a youth, his family moved to Ligao, Albay
, where he received his primary education. He finished his secondary education at San Beda College
in Manila
. Perfecto entered Colegio de San Juan de Letran
, where he received his Bachelor in Arts degree. He then enrolled in the law program of the University of Santo Tomas
, where he received his law degree. Perfecto passed the bar examinations
and was admitted to the Philippine Bar in 1916.
, in a series of decisions promulgated between 1921 and 1922.
, as a representative from the North District of Manila. He served until 1928. In 1931, Perfecto was stricken with polio and was left a cripple by the disease. Though he was unable to walk without the assistance of crutches, Perfecto recovered well enough to be able to resume playing golf.
Perfecto was a member of the Partido Democrata founded by Claro M. Recto
, eventually becoming its general secretary and general provisional president. Among the leaders of the Partido Democrata was then Senator
Sergio Osmeña
, who would later appoint him to the Supreme Court.
In 1934, Perfecto was elected a delegate to the Constitutional Convention that drafted the 1935 Constitution. After the constitution had been drafted, Perfecto had a doctor open a vein in his arm so he could sign the document using his own blood as ink. Following the approval of the Constitution in a plebiscite
, Perfecto was elected to represent the North District of Manila again in the National Assembly. He served in such capacity for two terms, from 1935 to 1941. He advocated for laws for the improvement of conditions for the employment of laborers, and for the grant of women's suffrage
.
Sergio Osmeña
to the Supreme Court, which had been reorganized following the end of the Japanese occupation of the Philippines. He served on the Court until his death in 1949.
In his four years on the Court, Perfecto authored 172 majority opinion
s and over 200 separate opinions, including 195 dissenting opinion
s. He is the only Justice in Philippine Supreme Court history to have penned more dissenting opinions than majority opinions. In all, Perfecto dissented 20.6% of the time during his tenure on the Court, there having been 945 decisions handed down during that period.
Impeachment
proceedings were initiated against Perfecto in Congress for converting his office into living quarters, though he had done so with the authorization of Chief Justice
Manuel Moran
on account of his physical disability. Perfecto charged that the attempts at impeachment, which were ultimately unsuccessful, were politically motivated.
and concurring opinion
s are better remembered than his majority opinions. Of the ponencias
he authored, the most consequential was Co Chiong v. Cuaderno, 83 Phil. 242 (1949) wherein the Court affirmed a law granting preference to Filipino citizens in the lease of public market stalls.
Perfecto's separate opinions give a clearer indication of his jurisprudential philosophy. His firm libertarian
views were fully expressed in several dissents. In Raquiza v. Bradford, 75 Phil. 50 (1945), he voted to grant habeas corpus
to three Filipinos detained by the United States military
as Japanese
spies, despite a proclamation from General Douglas MacArthur
ordering the indefinite detention
of Filipinos who collaborated with the Japanese Imperial Army during World War II. In Moncado v. People's Court, 80 Phil. 1 (1948), the majority refused to adopt the exclusionary rule as a consequence of an illegal search or seizure
. Perfecto wrote in dissent: “May the government profit from an illegality, an unconstitutional act, or even a crime to serve its aims, including the loftiest? May justice be administered by making use of the fruits of a lawless action?”
In In re Subido, 81 Phil 517 (1948), the majority had found a newspaper editor guilty of contempt
for prematurely but correctly reporting that the Court had voted to bar foreigners from acquiring agricultural lands in the Philippines in Krivenko v. Director of Lands, 79 Phil. 461. In his dissent, Perfecto admitted that he was the editor's source
for the report, but defended his action by observing that in the several months after the vote, before the decision was finally released, the issue had been widely debated in the media, and a rush had begun to complete the transfer of lands to foreigners. Perfecto also defended the editor, whom he said had performed a public service but was being punished for publishing the truth, and asserted that press freedom
was a constitutional right.
Dissenting in Dizon v. Commanding General, 81 Phil. 286 (1948), Perfecto argued that the grant of extraterritorial jurisdiction
to the United States government
over criminal offenses committed within American military base
s established through the 1947 RP-US Military Bases Agreement was unconstitutional, since the Constitution granted such jurisdiction only to Philippine courts. Perfecto criticized what he perceived as the servility of the Philippine government to the United States. “This Supreme Court has the power to stop the rampage of constitutional breaches in which other agencies of our government are indulging in a servile attitude of complaisance to former masters who are bent on keeping in their hands the strings, the chains, and the whip of unquestioned command. Our oath of office compels us to exercise that power. We do not entertain much respect for the Soviet satellites in Eastern and Central Europe. Shall we allow ourselves to go down in history as a mere American satellite?”
Perfecto was not hesitant in insisting upon judicial review
over acts of the executive or legislative branches of government, even against the defense that the issues raised were political questions. In Mabanag v. Lopez Vito, 78 Phil. 1 (1947), Perfecto dissented after the majority declined to examine whether the requisite votes in the House and Senate were obtained in the passage of an amendment to the Constitution
allowing American citizens the right to use and develop natural resource
s in the Philippines. In Avelino v. Cuenco, 83 Phil. 17 (1949) Perfecto again dissented when the majority refused to rule on the validity of the election of Mariano Jesús Cuenco
as acting Senate President. Perfecto opined that while the questions raised were political in nature, they were “justiciable because they involve the enforcement of legal precepts, such as the provisions of the Constitution and of the rules of the Senate.”
Tomas Cabili
, that “he must have deliberately used intemperate and exaggerated language, to the consternation of the bar and the bench, because it was the only effective means with which he could pierce through the fog of hazy understanding of the masses of what a real democracy means; perhaps he had to shout hard so many could hear him.”
Among some of Perfecto's more memorable passages are:
, he was reconciled with the Catholic Church shortly before his death.
Shortly before his death, Perfecto took the highly unusual step of filing in his behalf a petition with the Supreme Court arguing that the salaries of judges and justices were exempted from income tax
es by the Constitution. The case was decided in his favor after his death, though Justice Roman Ozaeta, in dissent, expressed that “[i]t is indeed embarrassing that this case was initiated by a member of this Court upon which devolves the duty to decide it finally.”
Several years after his death, many of the decisions Perfecto dissented from were overturned by the Supreme Court, most notably Moncado v. People's Court and Mabanag v. Lopez Vito.
In 1958, the City of Manila named a secondary school in Tondo, Manila
the Gregorio Perfecto High School
after the late Justice.
Philippines
The Philippines , officially known as the Republic of the Philippines , is a country in Southeast Asia in the western Pacific Ocean. To its north across the Luzon Strait lies Taiwan. West across the South China Sea sits Vietnam...
journalist
Journalist
A journalist collects and distributes news and other information. A journalist's work is referred to as journalism.A reporter is a type of journalist who researchs, writes, and reports on information to be presented in mass media, including print media , electronic media , and digital media A...
, politician
Politician
A politician, political leader, or political figure is an individual who is involved in influencing public policy and decision making...
and jurist
Jurist
A jurist or jurisconsult is a professional who studies, develops, applies, or otherwise deals with the law. The term is widely used in American English, but in the United Kingdom and many Commonwealth countries it has only historical and specialist usage...
who served as an Associate Justice
Associate Justice of the Supreme Court of the Philippines
An Associate Justice of the Supreme Court of the Philippines is one of 15 members of the Philippine Supreme Court, the highest court in the Philippines. The Chief Justice presides over the High Court, but carries only 1 of the 15 votes in the court...
of the Supreme Court of the Philippines
Supreme Court of the Philippines
The Supreme Court of the Philippines is the Philippines' highest judicial court, as well as the court of last resort. The court consists of 14 Associate Justices and 1 Chief Justice...
from 1945 to 1949. A controversial figure who was described as an “apostle of liberal causes”, Perfecto was notable for his libertarian
Libertarianism
Libertarianism, in the strictest sense, is the political philosophy that holds individual liberty as the basic moral principle of society. In the broadest sense, it is any political philosophy which approximates this view...
views, his colorful writing style, and the frequency of his dissenting opinion
Dissenting opinion
A dissenting opinion is an opinion in a legal case written by one or more judges expressing disagreement with the majority opinion of the court which gives rise to its judgment....
s while on the Supreme Court.
Early life
Perfecto was born in Mandurriao, IloiloMandurriao, Iloilo City
Mandurriao is one of the seven districts of Iloilo City, located in the Philippines. It is bounded by Molo to the south and west, City Proper to the south and east, and La Paz to the north....
. When he was a youth, his family moved to Ligao, Albay
Ligao City
Ligao City is a 4th class city in the province of Albay, Philippines. According to the 2007 census, it has a population of 101,179 people in 17,031 households. Ligao City is strategically located in the heart of the Third District of Albay...
, where he received his primary education. He finished his secondary education at San Beda College
San Beda College
San Beda College or Dalubhasaan ng San Beda in Filipino is a Private Benedictine college run by the Benedictine monks in the Philippines. It is located on Mendiola Street in San Miguel, Manila...
in Manila
Manila
Manila is the capital of the Philippines. It is one of the sixteen cities forming Metro Manila.Manila is located on the eastern shores of Manila Bay and is bordered by Navotas and Caloocan to the north, Quezon City to the northeast, San Juan and Mandaluyong to the east, Makati on the southeast,...
. Perfecto entered Colegio de San Juan de Letran
Colegio de San Juan de Letran
The Colegio de San Juan de Letran, Letran College, or simply Letran is a private Roman Catholic institution of learning located in Intramuros, Manila, in the Philippines. The college was founded in 1620. Colegio de San Juan de Letran has the distinction of being the oldest college in the...
, where he received his Bachelor in Arts degree. He then enrolled in the law program of the University of Santo Tomas
University of Santo Tomas
The Pontifical and Royal University of Santo Tomas, The Catholic University of the Philippines , is a private Roman Catholic university run by the Order of Preachers in Manila. Founded on April 28, 1611 by archbishop of Manila Miguel de Benavides, it has the oldest extant university charter in the...
, where he received his law degree. Perfecto passed the bar examinations
Philippine Bar Examination
The Philippine Bar Examination is the professional licensure examination for lawyers in the Philippines.It is the only professional licensure exam in the country that is not supervised by the Professional Regulation Commission...
and was admitted to the Philippine Bar in 1916.
Journalist
Perfecto practiced law for some time, then began a career for journalism as a reporter for the La Vanguardia and the Consolidacion Nacional newspapers. By 1919, Perfecto was the editor of the La Nacion daily newspaper. His tenure at La Nacion proved controversial, as he embarked on crusades against corruption and errant public officials. He was sued for criminal libel at least four times, the complaints being lodged by various local and national officials, including by the Philippine Senate. He was nonetheless acquitted of all charges by the Philippine Supreme CourtSupreme Court of the Philippines
The Supreme Court of the Philippines is the Philippines' highest judicial court, as well as the court of last resort. The court consists of 14 Associate Justices and 1 Chief Justice...
, in a series of decisions promulgated between 1921 and 1922.
Politician
In 1922, Perfecto was elected to the Philippine LegislatureCongress of the Philippines
The Congress of the Philippines is the national legislature of the Republic of the Philippines. It is a bicameral body consisting of the Senate , and the House of Representatives although commonly in the Philippines the term congress refers to the latter.The Senate is composed of 24 senators half...
, as a representative from the North District of Manila. He served until 1928. In 1931, Perfecto was stricken with polio and was left a cripple by the disease. Though he was unable to walk without the assistance of crutches, Perfecto recovered well enough to be able to resume playing golf.
Perfecto was a member of the Partido Democrata founded by Claro M. Recto
Claro M. Recto
Claro Mayo Recto, Jr. , was a Filipino politician, jurist, poet and one of the foremost statesmen of his generation...
, eventually becoming its general secretary and general provisional president. Among the leaders of the Partido Democrata was then Senator
Senate of the Philippines
The Senate of the Philippines is the upper chamber of the bicameral legislature of the Philippines, the Congress of the Philippines...
Sergio Osmeña
Sergio Osmeña
Sergio Osmeña y Suico was a Filipino politician who served as the 4th President of the Philippines from 1944 to 1946. He was Vice President under Manuel L. Quezon, and rose to the presidency upon Quezon's death in 1944, being the oldest Philippine president to hold office at age 65...
, who would later appoint him to the Supreme Court.
In 1934, Perfecto was elected a delegate to the Constitutional Convention that drafted the 1935 Constitution. After the constitution had been drafted, Perfecto had a doctor open a vein in his arm so he could sign the document using his own blood as ink. Following the approval of the Constitution in a plebiscite
Philippine constitutional plebiscite, 1935
This article on elections in the Philippines gives information on elections and election results in the Philippines. The 1935 Constitution was written in 1934, approved and adopted by the Commonwealth of the Philippines and later used by the Third Republic of the Philippines...
, Perfecto was elected to represent the North District of Manila again in the National Assembly. He served in such capacity for two terms, from 1935 to 1941. He advocated for laws for the improvement of conditions for the employment of laborers, and for the grant of women's suffrage
Women's suffrage
Women's suffrage or woman suffrage is the right of women to vote and to run for office. The expression is also used for the economic and political reform movement aimed at extending these rights to women and without any restrictions or qualifications such as property ownership, payment of tax, or...
.
Justice of the Supreme Court
In June 1945, Perfecto was appointed by PresidentPresident of the Philippines
The President of the Philippines is the head of state and head of government of the Philippines. The president leads the executive branch of the Philippine government and is the commander-in-chief of the Armed Forces of the Philippines...
Sergio Osmeña
Sergio Osmeña
Sergio Osmeña y Suico was a Filipino politician who served as the 4th President of the Philippines from 1944 to 1946. He was Vice President under Manuel L. Quezon, and rose to the presidency upon Quezon's death in 1944, being the oldest Philippine president to hold office at age 65...
to the Supreme Court, which had been reorganized following the end of the Japanese occupation of the Philippines. He served on the Court until his death in 1949.
In his four years on the Court, Perfecto authored 172 majority opinion
Majority opinion
In law, a majority opinion is a judicial opinion agreed to by more than half of the members of a court. A majority opinion sets forth the decision of the court and an explanation of the rationale behind the court's decision....
s and over 200 separate opinions, including 195 dissenting opinion
Dissenting opinion
A dissenting opinion is an opinion in a legal case written by one or more judges expressing disagreement with the majority opinion of the court which gives rise to its judgment....
s. He is the only Justice in Philippine Supreme Court history to have penned more dissenting opinions than majority opinions. In all, Perfecto dissented 20.6% of the time during his tenure on the Court, there having been 945 decisions handed down during that period.
Impeachment
Impeachment
Impeachment is a formal process in which an official is accused of unlawful activity, the outcome of which, depending on the country, may include the removal of that official from office as well as other punishment....
proceedings were initiated against Perfecto in Congress for converting his office into living quarters, though he had done so with the authorization of Chief Justice
Chief Justice of the Philippines
The Chief Justice of the Supreme Court of the Philippines presides over the Supreme Court of the Philippines and is the highest judicial officer of the government of the Philippines...
Manuel Moran
Manuel Moran
Manuel Moran was the Chief Justice of the Philippines from July 9, 1945 until March 20, 1951. After leaving office, he became the first Philippine Ambassador to Spain and the Holy See...
on account of his physical disability. Perfecto charged that the attempts at impeachment, which were ultimately unsuccessful, were politically motivated.
Jurisprudence
Perfecto's dissentingDissenting opinion
A dissenting opinion is an opinion in a legal case written by one or more judges expressing disagreement with the majority opinion of the court which gives rise to its judgment....
and concurring opinion
Concurring opinion
In law, a concurring opinion is a written opinion by one or more judges of a court which agrees with the decision made by the majority of the court, but states different reasons as the basis for his or her decision...
s are better remembered than his majority opinions. Of the ponencias
Majority opinion
In law, a majority opinion is a judicial opinion agreed to by more than half of the members of a court. A majority opinion sets forth the decision of the court and an explanation of the rationale behind the court's decision....
he authored, the most consequential was Co Chiong v. Cuaderno, 83 Phil. 242 (1949) wherein the Court affirmed a law granting preference to Filipino citizens in the lease of public market stalls.
Perfecto's separate opinions give a clearer indication of his jurisprudential philosophy. His firm libertarian
Libertarianism
Libertarianism, in the strictest sense, is the political philosophy that holds individual liberty as the basic moral principle of society. In the broadest sense, it is any political philosophy which approximates this view...
views were fully expressed in several dissents. In Raquiza v. Bradford, 75 Phil. 50 (1945), he voted to grant habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
to three Filipinos detained by the United States military
Military of the United States
The United States Armed Forces are the military forces of the United States. They consist of the Army, Navy, Marine Corps, Air Force, and Coast Guard.The United States has a strong tradition of civilian control of the military...
as Japanese
Empire of Japan
The Empire of Japan is the name of the state of Japan that existed from the Meiji Restoration on 3 January 1868 to the enactment of the post-World War II Constitution of...
spies, despite a proclamation from General Douglas MacArthur
Douglas MacArthur
General of the Army Douglas MacArthur was an American general and field marshal of the Philippine Army. He was a Chief of Staff of the United States Army during the 1930s and played a prominent role in the Pacific theater during World War II. He received the Medal of Honor for his service in the...
ordering the indefinite detention
Detention (imprisonment)
Detention is the process when a state, government or citizen lawfully holds a person by removing their freedom of liberty at that time. This can be due to criminal charges being raised against the individual as part of a prosecution or to protect a person or property...
of Filipinos who collaborated with the Japanese Imperial Army during World War II. In Moncado v. People's Court, 80 Phil. 1 (1948), the majority refused to adopt the exclusionary rule as a consequence of an illegal search or seizure
Search warrant
A search warrant is a court order issued by a Magistrate, judge or Supreme Court Official that authorizes law enforcement officers to conduct a search of a person or location for evidence of a crime and to confiscate evidence if it is found....
. Perfecto wrote in dissent: “May the government profit from an illegality, an unconstitutional act, or even a crime to serve its aims, including the loftiest? May justice be administered by making use of the fruits of a lawless action?”
In In re Subido, 81 Phil 517 (1948), the majority had found a newspaper editor guilty of contempt
Contempt of court
Contempt of court is a court order which, in the context of a court trial or hearing, declares a person or organization to have disobeyed or been disrespectful of the court's authority...
for prematurely but correctly reporting that the Court had voted to bar foreigners from acquiring agricultural lands in the Philippines in Krivenko v. Director of Lands, 79 Phil. 461. In his dissent, Perfecto admitted that he was the editor's source
Journalism sourcing
In journalism, a source is a person, publication, or other record or document that gives timely information. Outside journalism, sources are sometimes known as "news sources"...
for the report, but defended his action by observing that in the several months after the vote, before the decision was finally released, the issue had been widely debated in the media, and a rush had begun to complete the transfer of lands to foreigners. Perfecto also defended the editor, whom he said had performed a public service but was being punished for publishing the truth, and asserted that press freedom
Freedom of the press
Freedom of the press or freedom of the media is the freedom of communication and expression through vehicles including various electronic media and published materials...
was a constitutional right.
Dissenting in Dizon v. Commanding General, 81 Phil. 286 (1948), Perfecto argued that the grant of extraterritorial jurisdiction
Jurisdiction
Jurisdiction is the practical authority granted to a formally constituted legal body or to a political leader to deal with and make pronouncements on legal matters and, by implication, to administer justice within a defined area of responsibility...
to the United States government
Federal government of the United States
The federal government of the United States is the national government of the constitutional republic of fifty states that is the United States of America. The federal government comprises three distinct branches of government: a legislative, an executive and a judiciary. These branches and...
over criminal offenses committed within American military base
Military base
A military base is a facility directly owned and operated by or for the military or one of its branches that shelters military equipment and personnel, and facilitates training and operations. In general, a military base provides accommodations for one or more units, but it may also be used as a...
s established through the 1947 RP-US Military Bases Agreement was unconstitutional, since the Constitution granted such jurisdiction only to Philippine courts. Perfecto criticized what he perceived as the servility of the Philippine government to the United States. “This Supreme Court has the power to stop the rampage of constitutional breaches in which other agencies of our government are indulging in a servile attitude of complaisance to former masters who are bent on keeping in their hands the strings, the chains, and the whip of unquestioned command. Our oath of office compels us to exercise that power. We do not entertain much respect for the Soviet satellites in Eastern and Central Europe. Shall we allow ourselves to go down in history as a mere American satellite?”
Perfecto was not hesitant in insisting upon judicial review
Judicial review
Judicial review is the doctrine under which legislative and executive actions are subject to review by the judiciary. Specific courts with judicial review power must annul the acts of the state when it finds them incompatible with a higher authority...
over acts of the executive or legislative branches of government, even against the defense that the issues raised were political questions. In Mabanag v. Lopez Vito, 78 Phil. 1 (1947), Perfecto dissented after the majority declined to examine whether the requisite votes in the House and Senate were obtained in the passage of an amendment to the Constitution
Bell Trade Act
The Bell Trade Act of 1946, also known as the Philippine Trade Act was an act passed by the United States Congress specifying the economic conditions governing the independence of the Philippines from the United States....
allowing American citizens the right to use and develop natural resource
Natural resource
Natural resources occur naturally within environments that exist relatively undisturbed by mankind, in a natural form. A natural resource is often characterized by amounts of biodiversity and geodiversity existent in various ecosystems....
s in the Philippines. In Avelino v. Cuenco, 83 Phil. 17 (1949) Perfecto again dissented when the majority refused to rule on the validity of the election of Mariano Jesús Cuenco
Mariano Jesús Cuenco
Mariano Jesús Diosomito Cuenco was a Filipino Cebuano politician and writer.-Early life:He was born in Carmen, Cebu on January 16, 1888, to Mariano Albao Cuenco and Remedios López Diosomito. He studied at the Colegio de San Carlos of Cebu, where he graduated in 1904 with a degree in Bachelor of...
as acting Senate President. Perfecto opined that while the questions raised were political in nature, they were “justiciable because they involve the enforcement of legal precepts, such as the provisions of the Constitution and of the rules of the Senate.”
Writing style
In writing his opinions, Perfecto employed "picturesque language" which according to Justice Isagani Cruz had "earned him a special place in jurisprudence" and would "enliven generations of law students to come". After his death, it was suggested by his friend, SenatorSenate of the Philippines
The Senate of the Philippines is the upper chamber of the bicameral legislature of the Philippines, the Congress of the Philippines...
Tomas Cabili
Tomas Cabili
Tomas Lluisma Cabili was a lawyer, journalist, educator, and assemblyman from Lanao. He is also known as Sultan Dimasangkay-ko-Ranao for Maranaos.-Early life:...
, that “he must have deliberately used intemperate and exaggerated language, to the consternation of the bar and the bench, because it was the only effective means with which he could pierce through the fog of hazy understanding of the masses of what a real democracy means; perhaps he had to shout hard so many could hear him.”
Among some of Perfecto's more memorable passages are:
The present is liable to confusion. Our minds are subject to determinate and indeterminate ideological pressures. Very often man walks in the darkness of a blind alley obeying the pullings and pushings of hidden and unhidden forces, or the arcane predeterminations of the genes of human chromosomes.
Man is easily deceived into committing blunders or led into the most absurd aberrations. The mysterious genes which keep uninterrupted the chain of heredity, while permitting the transmission of the best qualities and characteristics, seems to lack the power of checking and staving off the tendencies of atavism. In the moral ctetology, either kind of characteristics and qualities may be originated and developed… To set two moral standards, a strict one for private individuals and another vitiated with laxity for the government, is to throw society into the abyss of legal ataxia. Anarchy and chaos will become inevitable. Such a double standard will necessarily be nomoctonous.
It is useless to panegyrize democracy as the best political system ever conceived, when once put into practice it is sabotaged by the double-dealing of the men on whose shoulders weighs the responsibility of making it a success. A sham democracy is a fertile breeding ground for any doxy that may offer the allurement of a promissory land, where the masses will enjoy better conditions of life.
Death
Perfecto died on August 17, 1949 after a brief illness. A FreemasonFreemasonry
Freemasonry is a fraternal organisation that arose from obscure origins in the late 16th to early 17th century. Freemasonry now exists in various forms all over the world, with a membership estimated at around six million, including approximately 150,000 under the jurisdictions of the Grand Lodge...
, he was reconciled with the Catholic Church shortly before his death.
Shortly before his death, Perfecto took the highly unusual step of filing in his behalf a petition with the Supreme Court arguing that the salaries of judges and justices were exempted from income tax
Income tax
An income tax is a tax levied on the income of individuals or businesses . Various income tax systems exist, with varying degrees of tax incidence. Income taxation can be progressive, proportional, or regressive. When the tax is levied on the income of companies, it is often called a corporate...
es by the Constitution. The case was decided in his favor after his death, though Justice Roman Ozaeta, in dissent, expressed that “[i]t is indeed embarrassing that this case was initiated by a member of this Court upon which devolves the duty to decide it finally.”
Several years after his death, many of the decisions Perfecto dissented from were overturned by the Supreme Court, most notably Moncado v. People's Court and Mabanag v. Lopez Vito.
In 1958, the City of Manila named a secondary school in Tondo, Manila
Tondo, Manila
Tondo is a district of Manila, Philippines. The locale has existed prior to the arrival of the Spanish, referred to as "Tundun" in the Laguna Copperplate Inscription. One of the most densely populated areas of land in the world, Tondo is located in the northwest portion of the city and is primarily...
the Gregorio Perfecto High School
Gregorio Perfecto High School
Gregorio Perfecto High School is a high school in Ricafort St. near Juan Luna, Tondo, Manila, Philippines that started as the Ismar annex of Florentino Torres High School.-History:...
after the late Justice.