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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 Malacañang.

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 PCCR’s creation. The
petitioner has failed to show that he is a real party in interest.
With regards to the petitioner’s 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.