G.R. No. A.M. No. 09-8-6-SC & A.M. No. 09-8-7-CA; June 13, 2012
RE: REQUEST FOR COPY OF 2008 STATEMENT OF ASSETS, LIABILITIES AND NETWORTH [SALN] AND PERSONAL DATA SHEET OR CURRICULUM VITAE OF THE JUSTICES OF THE SUPREME COURT AND OFFICERS AND EMPLOYEES OF THE JUDICIARY; RE: REQUEST OF PHILIPPINE CENTER FOR INVESTIGATIVE JOURNALISM [PCIJ] FOR THE 2008 STATEMENT OF ASSETS, LIABILITIES AND NET WORTH [SALN] AND PERSONAL DATA SHEETS OF THE COURT OF APPEALS JUSTICES.

FACTS

This consolidated administrative matter arose from multiple requests filed by various entities, including the Philippine Center for Investigative Journalism (PCIJ), media organizations, and private individuals, seeking copies of the Statements of Assets, Liabilities and Net Worth (SALNs) and Personal Data Sheets (PDS) of Justices of the Supreme Court, the Court of Appeals, and the Sandiganbayan. The requests cited purposes such as database updating, news reporting, academic study, and transparency advocacy. Notably, a subpoena from the Senate Impeachment Court in the case against Chief Justice Renato Corona was also included, demanding his SALNs. The Supreme Court consolidated these requests and created a special committee to review the policy on public access to such personal documents of members of the Judiciary.
The core legal conflict involved reconciling the constitutional right to information and the statutory mandate for public disclosure of SALNs under Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees) with the constitutional independence of the Judiciary and the right to privacy of its members. The Court had to determine the proper balance between transparency and the need to protect judicial officials from harassment or political pressure that could undermine their independence.

ISSUE

Whether the requests for copies of the SALNs and PDS of members of the Judiciary should be granted, and what are the governing rules and limitations for such public access?

RULING

The Supreme Court, exercising its constitutional power of administrative supervision over all courts, promulgated guidelines governing public access to SALNs of Justices, Judges, and court personnel. The Court recognized that while SALNs are public documents under R.A. 6713, access is not absolute and must be balanced against other constitutional rights. The ruling established that a specific, legitimate purpose must be shown by the requester; mere curiosity, fishing expeditions, or general claims of public interest are insufficient.
The legal logic is anchored on the constitutional principle of judicial independence. The Court held that unfettered access could expose judges to vindictive litigants, political harassment, or media exploitation, potentially chilling their decision-making freedom. Therefore, the right to information must be exercised within reasonable limits. The guidelines require a written request under oath, stating the exact purpose and the specific SALN or document sought, and an undertaking that the information will be used solely for the stated purpose. The Court designated the Clerk of Court as the custodian to evaluate requests based on these criteria. For requests concerning impeachable officers (Justices of the Supreme Court and the Collegiate Courts), the Court itself must grant approval. This framework ensures transparency is served while erecting necessary safeguards to preserve the integrity and independence of the judicial branch from undue external pressures.