CASTANEDA, MA. PATRICIA L.

Article III. Section 7. Information and Access to Official Records

Hilado v. Reyes 496 SCRA 282
FACTS:
Julita Campos Benedicto (private respondent), is the surviving spouse of the deceased Roberto
Benedicto. She was appointed Administratrix of his estate and the letters of administration were issued
in her favor. The case was presided by Judge Amor Reyes (public respondent).
Petitioners (Hilado, et. al.) had during the lifetime of Benedicto, filed before the RTC of Bacolod two
separate complaints for damages or collection of sums of money against Roberto Benedicto et al.
Petitioners counsel was denied access to the last folder-record of the case, which, according to the
clerical staff, could not be located and was probably in the chambers of the public respondent. The
judge denied their request for access to the files, as they were not parties to the case. Likewise, their
request for certified true copies of the order issued by the court during hearing, as well as the transcript
of stenographic notes taken thereon was denied. Thus the present petition for mandamus and prohibition.
ISSUES/HELD:
1. W/N the petition is fatally defective for failure of petitioners to disclose in the certificate of nonforum shopping that they had instituted an administrative complaint against the public respondent.
NO. It is only after a questioned action of a judge in a pending case has been judicially resolved with
finality that the door to an inquiry into his or her administrative liability may said to have opened.
2. W/N a writ of mandamus may issue to compel public respondent to allow petitioners to examine and
obtain copies of any or all documents forming part of the records of the case.
YES. Section 7 of Article III of the Constitution provides: The right of the people to information on
matters of public concern shall be recognized. Access to official records, and to documents and
papers pertaining to official acts, transactions, or decisions, as well as to government research data
used as basis for policy development, hall be afforded the citizen subject to such limitations as may
be provided by law. It is for the Courts to determine on a case-to-case basis whether the matter at
issue is of interest or importance as it relates to or affect the public. Unlike court orders and
decisions, pleadings and other documents filed by parties to a case need not be matters of public
concern or interest. Granting of unrestricted access and publicity to personal financial information
may constitute an unwarranted invasion of privacy. If information sought is not of public concern or
interest, denial of access thereto does not violate a citizens constitutional right to information.
In fine, access to court records may be permitted at the discretion and subject to the supervisory and
protective powers of the court. Petitioners stated main purpose for accessing the records to
monitor the prompt compliance with the Rules governing the preservation and proper disposition of
the assets of the estate appears legitimate, for as plaintiffs in the complaints for sum of money
against the deceased, they have an interest over the outcome of the settlement of his estate. Although
they are not parties to the case, they are interested persons.
3. W/N a writ of prohibition will issue in favor f the petitioners, who are not parties to the case, to
inhibit the public respondent from presiding over the case.
NO. Since the petitioners are not parties to the case, they may not seek public respondents inhibition.
Wherefore, the petition for mandamus is granted. Public petitioner is ordered to allow the petitioners
to access, examine and obtain copies of the any and all documents of the records bearing on the
inventory of assets and liabilities of the estate and the hearing conducted by the trial court. The
petition for prohibition is dismissed.