Legaspi v CSC 150 SCRA 530 (1987)

Facts:
The petitioner invokes his constitutional right to information on matters of public concern in a
special civil action for mandamus against the CSC pertaining to the information of civil service
eligibilities of certain persons employed as sanitarians in the Health Department of Cebu City.
The standing of the petitioner was challenged by the Solicitor General of being devoid of legal
right to be informed of the civil service eligibilities of government employees for failure of petitioner
to provide actual interest to secure the information sought.

Issue:
Whether or not petitioner may invoke his constitutional right to information in the case at bar.

Held:
The court held that when the question is one of public right and the object of the mandamus is to
procure the enforcement of a public duty, the people are regarded as the real party in interest and
the relator at whose instigation the proceedings are instituted need not show that he has any legal
or special interest in the result, it being sufficient to show that he is a citizen and as such interested
in the execution of the laws. The Constitution provides the guarantee of adopting policy of full
public disclosure subject to reasonable conditions prescribed by law as in regulation in the manner
of examining the public records by the government agency in custody thereof. But the
constitutional guarantee to information on matters of public concern is not absolute. Under the
Constitution, access to official records, papers, etc., are "subject to limitations as may be provided
by law" (Art. III, Sec. 7, second sentence). The law may therefore exempt certain types of
information from public scrutiny, such as those affecting national security.

The court delves into determining whether the information sought for by the petitioner is of public
interest. All appointments in the Civil Service Commission are made according to merit and fitness
while a public office is a public trust. Public employees therefore are accountable to the people
even as to their eligibilities to their positions in the government. The court also noted that the
information on the result of the CSC eligibility examination is released to the public therefore the
request of petitioner is one that is not unusual or unreasonable. The public, through any citizen,
has the right to verify the civil eligibilities of any person occupying government positions.