210) DE LEON V.

DUTERTE (2020)
TOPIC: Executive Department; To inform the Public of State of Health
DOCTRINE: The state of health or analysis as to the actual condition of the President should be left to
the President and his doctor and the burden is left to the Office of the President to choose the appropriate
means of releasing information to the public.
FACTS:

 Petitioner alleged that the President has been absent from several engagements due to health
reasons and also had prolonged absences from public view. Thus, Petitioner filed a Freedom of
Information (FOI) request under EO 2, with the Office of the President to clarify the status of
President’s health. Petitioner specifically asked for the copies of President’s latest medical
examination results, health bulletins, and other health records. Petitioner failed to get a response.
Thus, he filed for a petition of mandamus to compel the President to disclose all medical and
psychological/psychiatric examination results and other medical records ever since he assumed
Presidency.
ISSUE:
Whether or not petitioner may compel the President to disclose all the latter’s medical and
psychological/psychiatric examination results and other medical records ever since the latter assumed
Presidency.
RULING:
NO. According to the deliberations of Constitutional Commission on Section 12, Art. VII of the
Constitution, the state of health or analysis as to the actual condition of the President should be left to the
President and his doctor and the burden is left to the Office of the President to choose the appropriate
means of releasing information to the public.
Petitioner’s claims are merely based on what he perceived from online news articles discussing the
President’s illnesses. In recent months, the President has been visibly holding regular cabinet meetings,
belying Petitioner’s insinuation that President is suffering from serious illnesses. Further, the President’s
regular televised addresses to the nation as regards to government’s response to COVID-19 pandemic
show that the President has been actively performing his official duties. Apparently, petitioner’s
allegation that the President is seriously ill is unsubstantiated and is based merely on petitioner’s
conjectures regarding his perception of the declining health of the President.