Case Digest (G.R. No. 74930) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Valmonte et al. v. Belmonte, G.R. No. 74930, decided February 13, 1989, petitioners Ricardo Valmonte, Oswaldo Carbonell, Doy Del Castillo, Rolando Bartolome, Leo Obligár, Jun Gutierrez, Reynaldo Bagatsing, Jun “Ninoy” Alba, Percy Lapid, Rommel Corro and Rolando Fadul, all practitioners in media, sought a writ of mandamus with preliminary injunction against Feliciano Belmonte, Jr., then OIC General Manager of the Government Service Insurance System (GSIS). Petitioners requested (a) a list of opposition members of the former Batasang Pambansa who secured P2 million “clean loans” guaranteed by Mrs. Imelda Marcos; (b) certified true copies of the loan documents; or (c) access to public records demonstrating those transactions. Petitioner Valmonte first wrote Belmonte on June 4, 1986, invoking Article IV, Section 6 of the 1973 Freedom Constitution. The GSIS Deputy General Counsel refused on grounds of confidentiality on June 17, 1986. After a follow-up letter of June 20, 1986, pet Case Digest (G.R. No. 74930) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relief Sought
- Petitioners: Ricardo Valmonte et al., media practitioners and lawyers.
- Respondent: Feliciano Belmonte, Jr., GSIS General Manager.
- Relief: Writ of mandamus with preliminary injunction to compel disclosure under constitutional right to information:
- List of UNIDO and PDP-Laban Batasang Pambansa members who secured P2 million “clean” loans via Imelda Marcos.
- Certified true copies of documents evidencing their loans.
- Access to GSIS public records containing such information.
- Correspondence and Filing of Suit
- June 4, 1986 – Valmonte’s letter requesting list, loan documents, or access, invoking Freedom Constitution, Art. IV, Sec. 6.
- June 17, 1986 – Deputy General Counsel Tiro’s refusal citing GSIS–borrower confidentiality.
- June 20, 1986 – Follow-up letter asserting intent to pursue legal action.
- June 26, 1986 – Filing of special civil action for mandamus.
- Subsequent pleadings: respondent’s comment, Solicitor General’s intervention, reply, memoranda, submission for decision.
- Procedural Objection and Exception
- Respondent’s objection: failure to exhaust GSIS Board of Trustees remedies.
- Petitioners’ counter: raised pure question of law—scope of constitutional right to information—invoking exception to exhaustion rule.
Issues:
- Procedural Issue
- Does the exception to exhaustion of administrative remedies apply to purely legal questions on constitutional right to information?
- Substantive Issues
- Does mandamus lie to compel disclosure of GSIS loan documents under the constitutional right to information?
- Can petitioners compel respondent to prepare and furnish a list of MPs who obtained “clean” loans?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)