Legazpi vs CSC

Facts

The petitioner, Valentin Legaspi, invokes his constitutional right to information on

matters of public concern in a special civil action for mandamus against the CSC
pertaining to the information of civil service eligibilities of certain persons employed as
sanitarians in the Health Department of Cebu City. The standing of the petitioner was
challenged by the Solicitor General of being devoid of legal right to be informed of the
civil service eligibilities of government employees for failure of petitioner to provide
actual interest to secure the information sought.

Issues:

Whether or not the petitioner has the right to information as afforded him by the
Constitution

Held:

Yes. The court held that when the question is one of public right and the object of the
mandamus is to procure the enforcement of a public duty, the people are regarded as
the real party in interest and the relator at whose instigation the proceedings are
instituted need not show that he has any legal or special interest in the result, it being
sufficient to show that he is a citizen and as such interested in the execution of the
laws. The Constitution provides the guarantee of adopting policy of full public
disclosure subject to reasonable conditions prescribed by law as in regulation in the
manner of examining the public records by the government agency in custody thereof.
But the constitutional guarantee to information on matters of public concern is not
absolute. Under the Constitution, access to official records, papers, etc., are "subject
to limitations as may be provided by law" (Art. III, Sec. 7, second sentence). The law
may therefore exempt certain types of information from public scrutiny, such as those
affecting national security.

The court delves into determining whether the information sought for by the petitioner
is of public interest. All appointments in the Civil Service Commission are made
according to merit and fitness while a public office is a public trust. Public employees
therefore are accountable to the people even as to their eligibilities to their positions
in the government. The court also noted that the information on the result of the CSC
eligibility examination is released to the public therefore the request of petitioner is
one that is not unusual or unreasonable. The public, through any citizen, has the right
to verify the civil eligibilities of any person occupying government positions.

N.B.:

The Supreme Court of the Philippines held that government agencies have no
discretion to refuse disclosure of, or access to, information of public concern because
the Constitution guarantees access to such information. Valentin Legaspi, a citizen of
the Philippines, requested information regarding the civil service eligibility for
employees in the Health Department, which was rejected by the Civil Service
Commission. The Court reasoned that a citizen does not need to show any legal or
special interest in order to establish his or her right to information, and that the State
bears the burden of proving that the information is either exempt from disclosure by
law or that it is not of public concern.