G.R. No. 193636 - Gamboa vs. Chan

Petitioner Marynette R. Gamboa – then Mayor of Dingras, Ilocos Norte, alleged to maintain a private armed group (PAG).
Respondents Police Senior Superintendent Marlou C. Chan and Police Superintendent William O. Fang – officers of PNP‐Ilocos Norte tasked with intelligence and investigation.

Administrative Order No. 275 (8 December 2009) established an independent commission to investigate and dismantle private armies before the May 2010 elections.
The Commission, chaired by retired Justice Monina Arevalo-Zeñañosa, conducted surveillance and intelligence‐gathering through PNP and AFP assistance and submitted a confidential report, “A Journey Towards H.O.P.E.”

PNP-Ilocos Norte forwarded unverified surveillance data to the Commission, classifying Gamboa as maintaining a PAG (“Gamboa Group”).
Appendix A of the Report tabulated PAGs by region, listing her name first.
Portions naming Gamboa were broadcast on ABS-CBN evening news and appeared in print media, allegedly harming her reputation and subjecting her to surveillance.

Gamboa filed a Petition for Writ of Habeas Data (9 July 2010) seeking destruction and withdrawal of unverified reports, rectification of her honor, and prevention of future baseless data forwarding.
RTC Branch 13 issued the writ (14 July 2010), ordered respondents’ return and a summary hearing.
In their Return, respondents maintained their actions were within mandate and invoked pending criminal complaints against Gamboa; they also challenged the petition’s completeness and appropriateness.
RTC Decision (9 September 2010) found a privacy violation in her inclusion but dismissed the Petition for lack of proof linking respondents as the data source and for failure to implead the ZeAarosa Commission.

Whether the forwarding of PNP-Ilocos Norte intelligence to the ZeAarosa Commission, without prior verification or notice to Gamboa, violated her constitutional right to privacy in life, liberty or security.
Whether the writ of habeas data is the proper remedy for alleged reputational harm and unverified inclusion in the confidential Report.
Whether the ZeAarosa Commission was a necessary or indispensable party to the Habeas Data Petition.