Case Digest (G.R. No. 72119) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Valentin L. Legaspi v. Civil Service Commission (G.R. No. 72119, May 29, 1987), petitioner Valentin L. Legaspi, a private citizen and lawyer, filed a special civil action for Mandamus directly with the Supreme Court, invoking his fundamental right to information under the 1987 Constitution. He sought disclosure from the Civil Service Commission of the civil service eligibilities of two sanitarians, Julian Sibonghanoy and Mariano Agas, employed by the Health Department of Cebu City, alleging that they had represented themselves as certified eligibles for those positions. The Commission had denied his request, and no other plain, speedy, or adequate remedy existed because the denial was final and directly affected petitioner’s asserted constitutional right.Issues:
- Does petitioner, as a private citizen, have standing to invoke the writ of Mandamus to enforce the right to information on matters of public concern?
- Does the Civil Service Commission have a ministerial duty unde
Case Digest (G.R. No. 72119) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Petition
- Petitioner Valentin L. Legaspi filed a special civil action for Mandamus against the Civil Service Commission (CSC).
- He sought to compel the CSC to disclose the civil service eligibilities of two sanitarians, Julian Sibonghanoy and Mariano Agas, employed by the Health Department of Cebu City.
- Request and Denial
- Petitioner’s counsel inquired whether Sibonghanoy and Agas had passed the civil service examinations for sanitarians.
- The CSC denied the request, prompting Legaspi to invoke his constitutional right to information and to allege lack of any plain, speedy, and adequate remedy.
Issues:
- Standing to Sue
- Whether petitioner, as a private citizen, has “clear legal right” or direct interest to enforce the alleged public right.
- Whether the public‐right doctrine obviates the need for a special or pecuniary interest.
- Duty and Remedy
- Whether the CSC has a ministerial duty to disclose the eligibility records.
- Whether mandamus is the proper remedy to compel disclosure of information of public concern.
- Scope of Constitutional Guarantee
- Whether the civil service eligibility of public officers constitutes a “matter of public concern.”
- Whether any statute or regulation exempts civil service eligibility lists from public access.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)