G.R. No. 165036 - Antolin vs. Domondon

Petitioner Hazel Ma. C. Antolin took the Certified Public Accountant licensure examinations in October 1997. Out of 6,481 examinees, only 1,171 passed; Antolin failed four subjects.
Her grades were:

On November 3, 1997, Antolin was shown her shaded answer sheets but could not discern errors. On November 10, 1997, she formally requested copies of the questionnaire for each subject, her answer sheets, the answer keys, and grading explanations (“Examination Papers”).
Acting Chairman Domondon denied the requests, citing:

Section 36, Article III of the Rules and Regulations Governing the Regulation and Practice of Professionals (as amended by PRC Res. 332, s. 1994), which allows access only to answer sheets and reconsideration only for mechanical error or malfeasance; and
Section 20, Article IV of PRC Resolution 338, s. 1994, which prohibits reproduction or release of examination questions not sourced from a bank of at least 2,000 questions.

On January 12, 1998, Antolin filed a Petition for Mandamus with Damages and sought a preliminary mandatory injunction ordering the Board to furnish all Examination Papers and, if warranted, to revise her ratings and issue her CPA certificate.
Respondents opposed, arguing: lack of duty to release papers, availability of administrative remedy before the PRC, failure to exhaust remedies, and statutory confidentiality under PRC Resolution 338. They moved to dismiss the injunction after Antolin passed the May 1998 CPA exams and took her oath.
The RTC granted the motion to dismiss the preliminary injunction as moot. Antolin then filed a Second Amended Petition adding the PRC and again sought the papers and possible revision of her 1997 results.
On June 21, 2002, the RTC dismissed the petition as moot. On reconsideration (November 11, 2002), it set aside the dismissal, ordered the PRC to preserve and safeguard the Examination Papers, and remanded for further proceedings. Respondents’ motion for reconsideration was denied.

Respondents filed certiorari petitions (CA-GR SP No. 76498 and No. 76546). The CA, in separate decisions dated February 16, 2004 and December 11, 2006, respectively, set aside the RTC’s November 11, 2002 and January 30, 2003 orders and dismissed Civil Case No. 98-86881, holding that:

The case was moot upon Antolin’s passing of the 1998 exam;
PRC Resolution 338 validly limited access;
Examination Papers were not matters of public concern but personal to Antolin; and
Antolin failed to exhaust administrative remedies before the PRC.

Antolin’s petitions (G.R. Nos. 165036 and 175705) were consolidated due to similar facts and issues.
The Court considered:

Whether mandamus may compel access to the Examination Papers;
The applicability of the exhaustion of administrative remedies doctrine;
The constitutional right to information (Art. III, Sec. 7; Art. II, Sec. 28); and
Mootness in light of Antolin’s subsequent licensure.

Does Antolin have a clear legal right—and do respondents have a clear ministerial duty—to furnish her copies of the Examination Papers under the Constitution and enabling statutes?
Is mandamus an appropriate remedy, or must Antolin first exhaust administrative remedies before the PRC?
Has Antolin’s petition become moot by virtue of her passing the 1998 CPA examinations?