G.R. No. 175210 - Sereno vs. Committee on Trade and Related Matters of the National Economic and Development Authority

Petitioner Mario Jose E. Sereno, in his capacity as Executive Director of the Association of Petrochemical Manufacturers of the Philippines, Inc. (APMP), sought access to the minutes of the Committee on Tariff and Related Matters (CTRM) meeting of May 23, 2005, and all records underpinning Executive Order No. 486.
Respondent CTRM is an inter-agency advisory body under NEDA, composed of the NEDA Director-General, the Executive Secretary, Secretaries of Trade and Industry, Finance, Foreign Affairs, Agriculture, Environment and Natural Resources, Budget and Management, Transportation and Communication, Labor and Employment, Agrarian Reform, the Governor of the Bangko Sentral ng Pilipinas, and the Chairman of the Tariff Commission.

May 23, 2005 – CTRM resolves to recommend lifting the suspension of tariff reductions on petrochemicals and certain plastic products, prompting reduced CEPT rates via forthcoming executive order.
June 9 & 20, 2005 – APMP’s initial written request for minutes; denial citing confidentiality of member positions, but offering a summary of the action taken.
August 31, 2005 – Second denial invoking Section 3(c), Rule IV, IRR of R.A. 6713, analogizing CTRM meetings to closed-door Cabinet sessions.
October 27, 2005 – Follow-up APMP request emphasizing constitutional right to information; again denied.
December 12, 2005 & January 10, 2006 – APMP letters to the Office of the President urging rejection of CTRM recommendation; no response.
January 3, 2006 – Petition for mandamus filed before RTC, Pasig City (SCA No. 2903), with motion for preliminary mandatory injunction; opposition and motion to dismiss filed by CTRM.
January 12, 2006 – President issues Executive Order No. 486 lifting suspension of tariff reductions.
May 9, 2006 – RTC denies injunction, treating the case as a pure question of law.
October 16, 2006 – RTC dismisses mandamus petition for lack of merit, holding CTRM minutes privileged.
February 1, 2016 – Supreme Court resolves the direct appeal on questions of law.

Are CTRM meetings and their minutes exempt from the constitutional right of access to information on matters of public concern?
If the minutes are deemed privileged or confidential, is such privilege absolute?
May executive or deliberative privilege be used to evade public accountability or mask incompetence or malice?