Human Rights Access to Information

Alfredo Hilado, Manuel Lacson, Jose Tuvilla, Joaquin Limjap, Lopez Sugar
Corporation and First Farmers Holding Corporation vs Judge Amor Reyes and
Administratrix Benedicto
GR No. 163155; 21 July 2006

Ponente: Carpio-Morales, J.
Facts:
Petitioners had, during the lifetime of Benedicto, filed before Bacoloc RTC 2
complaints for damages for collection of sums of money against Roberto Benedicto.
Private respondent submitted the initial inventory of the estate, listing among other
liabilities, the claims of petitioners over P171M.
Branch Clerk of Court allowed petitioners, through counsel, to regularly and
periodically examine the records of the case and to secure certified true copies thereof
from January 2002 to November 2003. By December 2003, associate of petitioners
counsel was denied access to the last folder-record of the case.
Petitioners counsel requested to allow Atty Paredes to personally check the
records of the case. The Officer-in-charge of the branch advised that per instruction of
the judge, only parties or those with authority from parties are allowed to inquire and
verify the status of the case pending with the Court.
Petitioners counsel filed a Motion for Inhibition of public respondent on ground of
ignorance, dereliction of duty and manifest partiality towards the administratrix, which
was motion.
Judge Reyes, thru an Order, indicated why petitioners had no standing to file the
Motion for Inhibition as well as to request for certified true copies of documents. Hence
the petition.
Issue:
W/N the denial of petitioners access to any or all documents forming part of the
records of the case is unconstitutional
Held:
Yea. Petition for mandamus granted.
Ruling:
Section 7 of Art III, Consti - The right of the people to information on matters of public concern shall be
recognized. Access to official records, and to documents, and papers pertaining to official acts,
transactions, or decisions, as well as to government research data used as basis for policy development,
shall be afforded the citizen, subject to such limitations as may be provided by law.
Sec 7 guarantees a general rightthe right to information on matters of public
concern and, as an accessory thereto, the right of access to official records and the
like. The right to information on matters of public concern or public interest is both the
purpose and the limit of the constitutional right of access to public documents.
In determining whether a particular information is of public concern, there is no
right test. In the final analysis, it is for the courts to determine on a case to case basis
whether the matter at issue is of interest or importance as it relates to or affect the
public.
The Court holds that any party, counsel or person that has a legitimate reason to
have a copy of court records and pays court fees, a court may not deny access to such
records.
Being complainants for sum of money against Benedicto, petitioners have an
interest over the outcome of the settlement of Benedictos estate. The court finds the
petitioners being interest persons who have legitimate purpose for accessing the records
of the case.
[Petitioners contend that the records of the case are public records to which the public has the right to access, inspect
and obtain official copies thereof, recognition of which right is enjoined under Section 7, Art III of the Constitution and
Section 2, Rule 135 and Section 11, Rule 136 of the Rules of Court.
Private respondent submits that petition should be dismissed since petitioners are not parties to the case, hence, they
have no personality to file a motion for inhibition. ]