G.R. No. 225141 - Energy Regulatory Commission vs. Vega, Jr.

The petitioners, who are members of the Independence Commission and the Philippine Legislature, initiated an original action for the writ of mandamus.
The Independence Commission was created by Concurrent Resolution No. 20 (November 7, 1918) and confirmed by Joint Resolution No. 13 (March 8, 1919).
The petitioners include 30 legislators (26 from the House of Representatives and 4 from the Senate) and are all affiliated with the Democratic Party.

Leonard Wood – Governor-General of the Philippine Islands, exercising control over the executive department.
Manuel L. Quezon and Manuel Roxas – Chairmen of the Independence Commission.
Paciano Dizon – Acting Insular Auditor responsible for maintaining the original vouchers of the expenditures.
Teodoro M. Kalaw – Executive Secretary of the Independence Commission.
Fernando Mariano Guerrero – Secretary of the Independence Commission.

The petitioners are citizens, taxpayers, and legislators who are interested in monitoring the management and disbursement of public funds appropriated for the Independence Commission.
The petitioners assert that much of the funds are being allocated for purposes not conforming to the legal mandates of the Commission.

The petitioners sought a court order directing the respondents to exhibit and allow inspection and examination of all vouchers and documentary proofs regarding expenditures from funds appropriated under Act No. 2933.
Act No. 2933 appropriated one million pesos per annum for the expenses of the Independence Commission, with a standing provision to use unappropriated funds from the Insular Treasury.
The petitioners stressed that, as members of both the Legislature and the Commission, they have a legal and public duty to ensure that the funds are neither misused nor wasted.
It was alleged that, despite repeated written and verbal requests, the respondents had consistently refused access to the financial records, thereby denying the petitioners their constitutional rights.

Each respondent demurred to the petition on several grounds, asserting lack of jurisdiction and the discretionary nature of the acts complained of.
Defenses included:

The argument that the Governor-General, as head of the executive branch, is not subject to supervision or control by the judiciary.
The claim that the tasks of the Independence Commission and the custodianship of its records are inherently political and administrative in nature, thus outside the purview of judicial inquiry.
Reliance on statutory provisions, such as section 24 of the Jones Law, which confers exclusive administrative jurisdiction over accounts and related documents to the Auditor.
The contention that the petitioners have an alternate remedy through the Legislature, of which they are members, and that mandamus is not appropriate when a legal duty is discretionary.

Does the judicial department have authority to compel executive or legislative officers (specifically the Governor-General and other officers of the Independence Commission) to perform a duty through the writ of mandamus?
Is it within the court’s power to supervise the actions of coordinate departments of the Government given the principle of separation of powers?

Is there a clear, non-discretionary legal duty imposed upon the respondents to furnish and exhibit vouchers and documentary records of expenditures?
Do the facts allege any unlawful neglect on the part of the respondents in performing a ministerial act that courts can enforce by mandamus?

Have the petitioners exhausted other plain, speedy, and adequate remedies provided by law (i.e., addressing the matter internally within the Legislature or the Independence Commission)?
Do the petitioners possess any particular or individualized legal right separate from that of the public at large that would justify the issuance of the writ?