Title
Guingona, Jr. vs. Commission on Elections
Case
G.R. No. 191846
Decision Date
May 6, 2010
Citizens sought mandamus to compel Comelec to disclose election prep details amid mismanagement allegations, invoking constitutional rights to information and suffrage. Court granted partial relief, emphasizing transparency and public concern.

Case Digest (G.R. No. 191846)
Expanded Legal Reasoning Model

Facts:

  • Parties and Petition
    • Petitioners Teofisto Guingona, Jr., Bishop Leo A. Soriano, Fe Maria Arriola, Isagani R. Serrano, and Engr. Rodolfo Lozada filed a special civil action for mandamus on April 23, 2010 against the Commission on Elections (Comelec).
    • They invoked their constitutional rights to suffrage and to information, seeking full details of Comelec’s preparations for the May 10, 2010 automated elections.
  • Alleged Irregularities and Procurement Scandals
    • Smartmatic supplied wrong ultraviolet ink, leading to unreadable security marks and a P30 million purchase of UV lamps; contested purchases of P380-each ballot secrecy folders without public bidding and flawed indelible ink procurement.
    • PCOS machines malfunctioned in Hong Kong; Comelec approved a P500 million no-bid contract for ballot tracking; instituted emergency procurement; allowed reserve machines to transmit results without digital signatures; recalled 76,000 memory cards days before election.

Issues:

  • Standing and Justiciability
    • Whether petitioners, as private citizens, have legal standing and a clear cause of action to invoke mandamus for information.
    • Whether petitioners complied with any prerequisite demand on Comelec or exhaustion of administrative remedies.
  • Merits of the Right to Information
    • Whether the details of Comelec’s election preparations constitute a matter of public concern subject to constitutional disclosure.
    • Whether any law exempts Comelec from disclosing the information sought, thus barring mandamus relief.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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