Case Summary (G.R. No. 159699)
Background of Complaint and Procedural History
On September 9, 1975, Baldoza lodged a verified letter-complaint accusing Judge Dimaano of abuse of authority for allegedly refusing unrestricted public access to court dockets. The matter was referred to an investigating judge, Francisco Mat. Riodique, who conducted a preliminary hearing on October 16, 1975. A motion by Mayor Corazon A. Caniza to dismiss the complaint was denied. After formal inquiry, the investigating judge recommended exoneration, noting that Baldoza failed to present oral evidence and that documentary communications demonstrated no arbitrary refusal of access.
Respondent’s Defense and Regulation of Access
Judge Dimaano maintained that while court records are public documents, their inspection must be subject to reasonable regulations regarding who may inspect, when, where and how. He asserted authority to protect records from misuse, insisting that indiscriminate access might invite political tampering or scandal. He permitted inspection under his supervision and reserved the right to establish conditions to ensure orderly use.
Investigating Judge’s Findings
The investigating judge found that Dimaano allowed Baldoza to open and view the docket books under defined rules, which Baldoza acknowledged and accepted. No evidence showed the conditions to be unreasonable. The judge cautioned Baldoza about the potential repercussions of unfounded administrative charges against members of the judiciary, including erosion of public confidence.
Legal Principles on Access to Public Records
The Supreme Court recognized the public’s right to acquire information on matters of public concern and affirmed that access to official records may only be reasonably regulated, not prohibited outright. Citing prior decisions, the Court held that custodians of records have discretion to govern inspection procedures to prevent abuse but cannot deny legitimate access. Motive of the requester—unless pursuing an unlawful or purely idle curiosity—does not justify denial; remedies for wrongful publication lie with the legislature or in other legal actions against
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Facts of the Case
- On September 9, 1975, the Municipal Secretary of Taal, Batangas, filed a verified letter-complaint against Municipal Judge Rodolfo B. Dimaano for alleged abuse of authority.
- The complaint alleged that the judge refused to allow employees of the Municipal Mayor to examine criminal docket records needed for a report on peace and order.
- Respondent’s answer asserted no intention to deny access to public court records, but maintained that inspection must be reasonably regulated as to “who, when, where and how.”
- He argued a court may prevent improper use of its records and refuse copies to those lacking a serious and legitimate interest.
- Respondent cited past instances of partisan politics, tampering with the court’s door locks, and insisted on guidelines from the Supreme Court before granting broad access.
Procedural History
- The case was referred to Judge Francisco Mat. Riodique for investigation and report.
- At the October 16, 1975 preliminary hearing, Mayor Corazon A. Caniza moved to dismiss to preserve municipal harmony; the motion was denied.
- Complainant admitted having no oral evidence beyond written communications exchanged with the respondent.
- After formal investigation, the Investigating Judge recommended exoneration of the respondent.
Issues Presented
- Whether Judge Dimaano abused his authority by imposing conditions on inspecti