Arnaldo v. Locsin

Summary

This certiorari case involved the propriety of a subpoena duces tecum issued by a Court of First Instance judge ordering the production of various documents, including income tax returns and business records, in a family debt dispute. Petitioner Julita Sarayba de Arnaldo challenged the court's order requiring her to produce documents for deposition, arguing many were irrelevant and that income tax returns could not be compelled. The Supreme Court granted certiorari, ruling that courts cannot compel production of income tax returns not in the litigant's possession or documents lacking relevancy to the case. The decision established important limitations on judicial power to issue subpoenas duces tecum, protecting individuals from unjust inquisition of private records and requiring clear showing of materiality and relevance before compelling document production in civil proceedings.