Case Digest (G.R. No. 21327)
Facts:
Teodoro Abueva et al. v. Leonard Wood et al., G.R. No. 21327, January 14, 1924, the Supreme Court En Banc, Johnson, J., writing for the Court.Petitioners were members of the Independence Commission created by Concurrent Resolution No. 20 (Nov. 7, 1918) and ratified by Joint Resolution No. 13 (Mar. 8, 1919); they were also members of the Philippine Legislature elected June 6, 1922. They sought an original writ of mandamus in the Supreme Court to compel respondents to exhibit and permit inspection of all vouchers and documentary proofs showing disbursements made from the P1,000,000 standing appropriation (Act No. 2933) for the Independence Commission.
Respondents included Leonard Wood (Governor-General), Manuel L. Quezon and Manuel Roxas (chairmen/presidents of the Independence Commission), Paciano Dizon (Acting Insular Auditor), Teodoro M. Kalaw (Executive Secretary of the Commission), and Fernando Mariano Guerrero (Secretary of the Commission). The Attorney-General entered appearances for these respondents and demurred to the petition on multiple grounds: lack of jurisdiction because the requested relief would control actions of coordinate branches (executive and legislative); that the Auditor has exclusive jurisdiction over accounts and vouchers under the Jones Law (Act of Congress, Aug. 29, 1916, sections 24–25); that mandamus will not lie absent a legal duty to produce records; that the matter is political/confidential or discretionary; and that petitioners had other remedies (through the Commission or the Legislature).
The petition alleged petitioners had repeatedly requested access to vouchers and that respondents refused. The Attorney‑General filed an extensive memorandum supporting the demurrers; petitioners did not file a supporting memorandum. The Supreme Court treated the case as raising separation‑of‑powers and jurisdict...(Subscriber-Only)
Issues:
- May the courts issue a writ of mandamus directing the Governor‑General to permit petitioners to inspect the Independence Commission vouchers?
- May the courts issue a writ of mandamus directing officers of a legislative committee (the Independence Commission) to exhibit their records to petitioners?
- May the courts compel the Acting Insular Auditor to produce vouchers and records of the Independence Commission in light of the Jones Law's grant o...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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