Global Freedom of Expression

Legaspi v. Civil Service Commission

Closed Expands Expression

Key Details

  • Mode of Expression
    Public Documents
  • Date of Decision
    May 29, 1987
  • Outcome
    Access to Information Granted
  • Case Number
    G.R. No. 72119.
  • Region & Country
    Philippines, Asia and Asia Pacific
  • Judicial Body
    Supreme (court of final appeal)
  • Type of Law
    Constitutional Law, Law of Evidence
  • Themes
    Access to Public Information
  • Tags
    Exceptions to the Right of Access to Information, Public Interest

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Case Analysis

Case Summary and Outcome

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.

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Valentin Legaspi, a citizen of the Philippines, had requested information from the Civil Service Commission regarding the civil service eligibility of sanitation employees in the Health Department of Cebu City. The Commission rejected the request asserting that Legaspi was not entitled to the information. Legaspi then instituted an action asking the Court to compel the Civil Service Commission to provide the information.

Decision Overview

The Court began by noting that both the 1973 (Art. IV, Sec. 6) and 1987 (Art. III, Sec. 7) constitutions recognize the right of the people to information on matters of public concern. Further, they specify that information shall be provided, subject only to limitations provided by law.

While the Solicitor General interposed a procedural objection challenging the requester’s standing in this petition, the Court ruled that, in this case, the people are regarded as the “real party in interest” and the requester, as a citizen interested in the execution of the laws, did not need to show any legal or special interest in the result. [p. 2] Further, government agencies have no discretion to refuse disclosure of, or access to, information of public concern because the Constitution guarantees access to information of public concern, a recognition of the essential nature of the free flow of ideas and information in a democracy. The government agency denying information access has the burden to show that the information is not of public concern, or, if it is of public concern, that the information has been exempted by law from the obligation of disclosure.

Here, the information was of public concern because it is the legitimate concern of citizens to ensure that government positions requiring civil service eligibility are occupied only by eligible persons, and the Civil Service Commission failed to cite any law limiting the requester’s right to know. Thus, the Court ordered the Civil Service Commission to provide the information.

Decision Direction

Quick Info

Decision Direction indicates whether the decision expands or contracts expression based on an analysis of the case.

Expands Expression

This case expands expression because it upholds the individuals right to request information from governmental agencies and places the burden of proof on the government to justify any refusals to provide access to information.

Global Perspective

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Global Perspective demonstrates how the court’s decision was influenced by standards from one or many regions.

Table of Authorities

National standards, law or jurisprudence

  • Phil., Tanada et. al. vs Tuvera et. al., G.R. No. L-63915 (1985)
  • Phil., Consitution 1973, art. IV section 6
  • Phil. Land Registration Act, sec. 56
  • Phil., Subido v Ozaeta, 80 Phil. 383 [1948]
  • Phil., Anti-Chinese League of the Philippines vs. Felix, 77 Phil. 1012 [1947]
  • Phil., Baldoza v Dimaano, Adm. Matter No. 1120-MJ (1976)

Other national standards, law or jurisprudence

  • U.S., Thornhill v. Alabama, 310 U.S. 88 (1940)

Case Significance

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Case significance refers to how influential the case is and how its significance changes over time.

The decision establishes a binding or persuasive precedent within its jurisdiction.

Official Case Documents

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