CASE DIGEST
Right to Access to Information (Art. 3, Sec. 7)
Valmonte v. Belmonte, G.R. No. 74930, Feb 13, 1989
Facts:
Petitioners, led by Ricardo Valmonte, filed a petition for mandamus to compel the GSIS to disclose
documents evidencing loans granted to members of the Batasang Pambansa, including opposition
members, allegedly with the intervention of Imelda Marcos. The petitioners argued that their
constitutional right to information on matters of public concern, as provided under the 1973
Constitution, entitled them to access these records. The GSIS and its officials refused, citing
confidentiality and privacy concerns, and the case was filed before the courts. The Court recognized the
public character of GSIS funds and the importance of transparency in managing public resources,
especially given the loans' potential impact on public funds and accountability.
Issues:
1) Whether petitioners are entitled to access the documents evidencing the loans under their
constitutional right to information. Specifically, whether the right to information extends to
documents of a government-owned corporation like GSIS
2) Whether the confidentiality and privacy rights can override the right to information.
Ruling of the Supreme Court:
The Court ruled in favor of the petitioners, holding that the constitutional right to information includes
access to documents related to transactions involving public funds, such as those of GSIS, which
manages public resources. The Court emphasized that the public nature of GSIS funds and the public
office held by the borrowers make such information a matter of public concern. However, the Court
denied the request for a list of names, stating that the right to information does not include the right to
compel the preparation of lists or summaries. The Court ordered GSIS to allow access to the loan
documents under reasonable regulations.
Doctrine Applied:
The Court reaffirmed that the right to information is fundamental and applicable to government
agencies and corporations performing public functions, especially when public funds are involved. It
emphasized that this right is limited to matters of public concern and that confidentiality or privacy
cannot be invoked to deny access to documents related to public resources, aligning with principles of
transparency and accountability in environment and natural resources management.
