Baldoza v. Dimaano, 71 SCRA 14 (1976)

Baldoza v. Dimaano, 71 SCRA 14 (1976) ​

FACTS:

• In a verified letter-complaint dated September 9, 1975, the Municipal Secretary of Taal, Batangas, charged Municipal Judge Rodolfo B. Dimaano with abuse of authority in refusing to allow employees of the Municipal Mayor to examine the criminal docket records of the Municipal Court to secure data in connection with their contemplated report on the peace and order conditions of the said municipality.
• In answer, Dimaano stated that there has never been an intention to refuse access to official court records; that although court records are among public documents open to inspection not only by the parties directly involved but also by other persons who have legitimate interest to such inspection, yet the same is always subject to reasonable regulation as to who, when, where and how they may be inspected. He further asserted that a court has unquestionably the power to prevent an improper use or inspection of its records and the furnishing of copies therefrom may be refused where the person requesting is not motivated by a serious and legitimate interest but acts out of whim or fancy or mere curiosity or to gratify private spite or to promote public scandal.
• The case was then referred to Judge Francisco Mat. Riodique for investigation and report.
• At the preliminary hearing on 16 October 1975, Taal Mayor Corazon A. Cañiza filed a motion to dismiss the complaint to preserve harmony and cooperation among officers in the same municipality. This motion was denied by the Investigating Judge, but after formal investigation, he recommended the exoneration of Dimaano.

 
ISSUE: 
Whether the rules and conditions imposed by Judge Dimaano on the inspection of the docket books infringe upon the right of individuals to information.
 
RULING:
No. Judge Dimaano did not act arbitrarily in the premise. As found by the Investigating Judge, Dimaano allowed the complainant to open and view the docket books of Dimaano under certain conditions and under his command and supervision. It has not been shown that the rules and conditions imposed by Dimaano were unreasonable. The access to public records is predicated on the right of the people to acquire information on matters of public concern. Undoubtedly in a democracy, the public has a legitimate interest in matters of social and political significance. The New Constitution expressly recognizes that the people are entitled to information on matters of public concern and thus are expressly granted access to official records, as well as documents of official acts, or transactions, or decisions, subject to such limitations imposed by law. The incorporation of this right in the Constitution is a recognition of the fundamental role of free exchange of information in a democracy. There can be no realistic perception by the public of the nation's problems, nor a meaningful democratic decision-making if they are denied access to information of general interest. Information is needed to enable the members of society to cope with the exigencies of the times. As has been aptly observed: "Maintaining the flow of such information depends on protection for both its acquisition and its dissemination since, if either process is interrupted, the flow inevitably ceases." However, restrictions on access to certain records may be imposed by law. Thus, access restrictions imposed to control civil insurrection have been permitted upon a showing of immediate and impending danger that renders ordinary means of control inadequate to maintain order.