Gonzales v Narvasa G.R. No.

140835, August 14, 2000 Facts: On December 9, 1999, a petition for prohibition and mandamus was filed assailing the constitutionality of the creation of the Preparatory Commission on Constitutional Reform (PCCR) and of the positions of presidential consultants, advisers and assistants. In his capacity as citizen and as taxpayer, he seeks to enjoin the Commission on Audit from passing in audit expenditures for the PCCR and the presidential consultants, advisers and assistants. Petitioner also prays that the Executive Secretary be compelled through a mandamus to furnish the petitioner with information requesting the names of executive officials holding multiple positions in government, copies of their appointments and a list of the recipients of luxury vehicles seized by the Bureau of Customs and turned over to Malacaang.

Issue: Whether or not petitioner possesses the requisites of filing a suit as a citizen and as taxpayer.

Ratio Decidendi: The Court ruled that the petitioner did not have standing to bring suit as citizen. Petitioner did not in fact show what particularized interest they have to bring the suit. As civic leaders, they still fall short of the requirements to maintain action. Their interest in assailing the EO does not present to be of a direct and personal character. Furthermore, they do not sustain or are in immediate danger of sustaining some direct injury as a result of its enforcement. As taxpayers, petitioners cannot attack the EO. There is no appropriation granted from Congress but only an authorization by the president. There being exercise by Congress of its taxing and spending power, petitioner cannot be allowed to question the PCCRs creation. The petitioner has failed to show that he is a real party in interest. With regards to the petitioners request of disclosure to public information, the Court upheld that citizens may invoke before the courts the right to information. When a mandamus proceeding involves the assertion of a public right, the requirement of personal interest is satisfied by the mere fact that the petitioner is a citizen. The Supreme Court dismissed the petition with the exception that respondent Executive Secretary is ordered to furnish petitioner with the information requested.