G.R. No. 199166 - Begino vs. ABS-CBN Corp.

Petitioner, Abelardo Subido, editor of The Manila Post, filed a petition for mandamus against respondents Roman Ozaeta, Secretary of Justice, and Mariano Villanueva, Register of Deeds of Manila.
Petitioner sought an order compelling respondents to:

Furnish a list of real estate sold to aliens and registered in the Register of Deeds of Manila since the issuance of DOJ Circular No. 128, or
Allow petitioner or his duly accredited representatives to examine all records related to such transactions in respondents' custody.

The Register of Deeds denied the first alternative (furnishing a list), and the Secretary of Justice upheld this denial on appeal. No formal request to inspect the records was made by the petitioner, but the Solicitor General indicated such inspection would be disallowed.

Inspection of records may be made only by those with a special interest and subject to reasonable regulations prescribed by the Chief of the Land Registration Office.
The Secretary of Justice reasonably ruled that records cannot be disclosed for publication to safeguard public and private interests.

Petitioner grounded part of the petition on the constitutional liberty of the press.

Section 56 of Act No. 496, as amended by Act No. 3300, provides that all records relating to registered lands in the office of the Register of Deeds shall be open to the public subject to reasonable regulations prescribed by the Chief of the General Land Registration Office with approval of the Secretary of Justice.
There were no known regulations adopted by the Chief of the General Land Registration Office to govern the inspection of these records.
The Register of Deeds claimed inherent power to regulate access to the records to prevent damage, loss, or undue interference with official duties.

Petitioner wanted access to examine records of sales of real property to aliens to verify rumors of constitutional violations and alleged corrupt enrichment of public officials through real estate acquisitions.
The Manila Post was engaged in a strong campaign against alienation of land to foreigners and sought to publish truthful information on the subject.

Justice Briones partially dissented, emphasizing that the denial of access constituted a restriction or prior censorship against the freedom of the press guaranteed by the Constitution.
Justice Pablo dissented on procedural grounds, arguing that the petition lacked allegations that petitioner actually requested inspection and was denied, thus rendering the petition defective for mandamus relief.

Whether the petitioner, as a member of the press, has the right to access and examine public records of land sales to aliens in the Register of Deeds’ custody.
Whether the respondents can lawfully restrict or prohibit the petitioner’s examination of such records in the absence of a statute or formal regulations.
Whether the refusal to allow examination of records constitutes a violation of the constitutional freedom of the press.
Whether mandamus is the appropriate remedy to compel respondents to allow inspection of the records.