Bataan Shipyard vs PCGG (GR 75885, May 27, 1987)

Facts:
Pursuant to the Executive Order No. 1 and 2 promulgated by President Aquino,
the PCGG was ordered to recover ill-gotten wealth amassed by former
President Marcos, his relatives, cronies and associates, which were obtained
through the use of public funds. Consequently, the Presidential Commission on
Good Government issued a sequestration order against petitioner BASECO.
Incidental to this, the petitioner was ordered to produce its corporate records
from 1973 to 1986. In assailing this order, petitioner contended that this
violates its constitutional right against self-incrimination.

Issue:
Is a corporation entitled to the right against self-incrimination afforded to
individuals by the Constitution?

Held:
The Court held in the negative. The Court found that BASECO was owned by
President Marcos through the use of dummies and alter egos, most notable
evidence being the recovery of the deed of assignments of shares in the
company in the Malacañang after the flight of the Marcoses. It was the ruling of
the Court that the right against self-incrimination has no application to
juridical person. In addition, an officer of a company cannot refuse the
production of records on the ground of it incriminating him or the company.
The Court quoted the ruling of Wilson vs. US, to the effect that the corporation
is a mere creature of the state. This being so, there is a reservation to the
legislature to investigate its contracts and find out whether it has exceeded its
powers. The Court also held that there was no violation of its right against
unlawful search and seizure since no search or seizure took place.