G.R. No. L-72119 May 29, 1987
VALENTIN L. LEGASPI, petitioner, vs. CIVIL SERVICE COMMISSION, respondent.

FACTS

Petitioner Valentin L. Legaspi filed a special civil action for mandamus to compel the Civil Service Commission (CSC) to disclose information regarding the civil service eligibilities of Julian Sibonghanoy and Mariano Agas, who were employed as sanitarians in the Health Department of Cebu City. Legaspi invoked the constitutional right of the people to information on matters of public concern, asserting that these employees had represented themselves as civil service eligibles. The CSC denied his request, prompting this suit.
The Solicitor General, representing the CSC, raised procedural objections, challenging Legaspi’s legal standing. He argued that Legaspi failed to demonstrate a personal or specific interest in the information sought and that the CSC had no ministerial duty to furnish such data to him. The core contention was whether a private citizen, without showing a direct personal interest, could compel a government agency to disclose information under the constitutional guarantee.

ISSUE

The primary issue is whether a private citizen has the right, via mandamus, to compel a government agency to disclose information on the civil service eligibility of public employees under the constitutional right to information on matters of public concern.

RULING

The Supreme Court granted the petition, ruling that mandamus lies to enforce the constitutional right to information. The Court held that the constitutional provisions on the right to information are self-executing and do not require legislative implementation to be operative. This right, recognized under Article III, Section 7 of the 1987 Constitution (and its precursor in the 1973 Constitution), guarantees public access to official records pertaining to official acts, subject only to limitations provided by law.
On the issue of standing, the Court ruled that when a mandamus proceeding involves the assertion of a public right, the requirement of personal interest is satisfied by the petitioner’s status as a citizen. The right to information is a public right, and any citizen, as part of the general public, has the standing to enforce it. The information sought—the civil service eligibility of government employees—is a matter of public concern. Public office is a public trust, and appointments must be based on merit and fitness. Citizens have a legitimate interest in ensuring that positions requiring civil service eligibility are occupied by qualified eligibles.
The Court further found that the CSC failed to cite any legal provision exempting civil service eligibility information from disclosure. Judicial notice was taken that lists of successful civil service examinees are publicly released. Therefore, there is no confidentiality attached to such eligibility. The duty of the CSC to confirm or deny the eligibility of the employees in question is imperative. Consequently, the CSC was ordered to open its register of eligibles for the position of sanitarian and to confirm or deny the eligibility of Sibonghanoy and Agas as requested by Legaspi.