Gregorio Perfecto (November 28, 1891 – August 17, 1949) 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 opinions while on the Supreme Court.
Perfecto was born in Mandurriao, Iloilo. 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 of 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.
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 Court, in a series of decisions promulgated between 1921 and 1922.
In 1922, Perfecto was elected to the Philippine Legislature, as a representative from the North District of Manila. He served until 1928. In 1931, Perfecto was stricken with polio and was left crippled 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.
In June 1945, Perfecto was appointed by President 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 opinions and over 200 separate opinions, including 195 dissenting opinions. 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.
Perfecto died on August 17, 1949 after a brief illness. A Freemason, 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 taxes 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.