G.R. No. 140835, August 14, 2000. RAMON A. GONZALES, petitioner, vs. HON. ANDRES R. NARVASA, as Chairman, PREPARATORY COMMISSION ON CONSTITUTIONAL REFORMS; HON. RONALDO B. ZAMORA, as Executive Secretary; COMMISSION ON AUDIT; ROBERTO AVENTAJADO, as Presidential Consultant on Council of Economic Advisers/Economic Affairs; ANGELITO C. BANAYO, as Presidential Adviser for/on Political Affairs; VERONICA IGNACIO-JONES, as Presidential Assistant/ Appointment Secretary (In charge of appointments), respondents.
FACTS

Petitioner Ramon A. Gonzales, as a citizen and taxpayer, filed a petition for prohibition and mandamus assailing the constitutionality of the Preparatory Commission on Constitutional Reform (PCCR) created by President Estrada through Executive Order No. 43. He also challenged the validity of the positions of various presidential consultants, advisers, and assistants. Petitioner sought to enjoin these bodies and officials from acting, to stop the Commission on Audit from auditing their expenditures, and to compel Executive Secretary Ronaldo Zamora to furnish him with information on certain official matters.
Respondents argued that the case against the PCCR had become moot. The PCCR, initially tasked to complete its work by June 30, 1999, had its term extended to December 31, 1999, by Executive Order No. 70. The Commission submitted its recommendations on December 20, 1999, and was dissolved on the same day, having exhausted its allotted funds.

ISSUE

The primary issues were: (1) whether the petition regarding the PCCR had been rendered moot and academic; (2) whether petitioner had legal standing to challenge the creation of the PCCR and the presidential positions; and (3) whether petitioner was entitled to the information requested from the Executive Secretary.

RULING

The Supreme Court dismissed the petition, except for the order regarding the request for information. On the PCCR, the Court ruled the issue was moot. A case becomes moot when it no longer presents a justiciable controversy. The PCCR had completed its task, submitted its report, and was dissolved. The relief sought—to enjoin the PCCR from acting—was impossible to grant as the body no longer existed. Prohibition does not lie against a fait accompli. Any ruling would be an advisory opinion, which is beyond judicial power.
Furthermore, petitioner lacked standing to challenge the PCCR. Standing requires a personal and substantial interest showing direct injury from the challenged act. Petitioner asserted only a general interest as a citizen and taxpayer. The Court, citing Kilosbayan, Incorporated v. Morato, held that such generalized interest is insufficient unless the petitioner demonstrates a direct injury, such as an illegal disbursement of public funds specifically affecting him as a taxpayer. No such showing was made here.
Regarding the presidential consultants and advisers, the Court found petitioner also lacked standing. He failed to demonstrate any personal and direct injury from their creation and operation. The general constitutional principle of separation of powers does not grant citizens a automatic right to challenge every presidential action without a specific, concrete injury.
However, on the request for information, the Court partially granted the petition. Citing the constitutional right to information on matters of public concern and the case of Legaspi v. Civil Service Commission, the Court held that the Executive Secretary must afford petitioner access to the requested documents, such as appointment papers, subject to reasonable regulations for the orderly conduct of official business. This right is enforceable by mandamus.