Legaspi vs. COMELEC

A petition for certiorari and mandamus seeking a manual recount of election results based on unsubstantiated surmises and unfounded conjectures must be dismissed where petitioners lack personal knowledge to verify their pleadings, lack locus standi, fail to exhaust administrative remedies under the agency's FOI manual, and cannot point to any clear legal right to the relief sought. The constitutional right of suffrage does not encompass a right to a full manual recount of an entire province's election results based on speculation, and the constitutional right to information on matters of public concern requires a prior, specific, and proper demand for access to particular documents before mandamus may lie.

Petitioners are 32 registered voters from 9 cities and municipalities in the Province of Pangasinan who participated in the May 9, 2022 National and Local Elections. They doubt the integrity of the automated election system, citing the unusual speed of result transmission, supposedly high voter turnout, and discrepancies with pre-election surveys. The constitutional framework at issue includes the right of suffrage, the right to information on matters of public concern (Article III, Section 7 of the 1987 Constitution), and the right to petition the government for redress of grievances. COMELEC had promulgated Resolution No. 10685 in December 2020, adopting a comprehensive FOI Manual that provides a procedure for citizens to request access to information in COMELEC's custody, including an administrative appeal process for denials and a presumption in favor of disclosure.

Petitioners are 32 registered voters from 9 cities and municipalities in the Province of Pangasinan who cast their votes in the May 9, 2022 National and Local Elections. They doubt the results of the automated election system, citing the unusual speed of transmission of election results, supposedly high voter turnout in Pangasinan, and discrepancies between the actual results and pre-election surveys. Their concerns were further fueled by opinions, observations, and postings online from various experts pointing to the statistical improbability of the election results, as summarized in an unsigned and unverified "Summary of Viral Social Media Postings."

Through petitioner Atty. Laudemer I. Fabia, the group prepared and circulated a signature campaign petition entitled "APELA PARA SA MANO-MANONG PAGBILANG MULI NG MGA BOTO SA PROBINSYA NG PANGASINAN" (APELA), which was received by COMELEC's Executive Director on May 27, 2022. The APELA, forwarded from COMELEC's Provincial Election Supervisor in Pangasinan, was signed by a certain Albert O. Quintinita, who is not a party to the instant petition. The APELA sought a manual recount of the votes in Pangasinan, alleging widespread electoral fraud. Only the first page containing the paragraphs of intent was attached to the instant petition; the critical signature pages supporting the campaign were notably absent from the record.

COMELEC's Law Department replied to Quintinita in a Letter dated May 31, 2022, advising that the document did not state the position involved and other details required for an election protest. The letter explained that contests for elective regional, provincial, or city officials must be filed directly with COMELEC by a candidate who received the second or third highest number of votes, while contests for municipal officials must be filed before the proper Regional Trial Court by a similarly situated candidate.

Dissatisfied, Atty. Fabia, as spokesperson for the affected voters, sent a Letter dated June 15, 2022 seeking reconsideration. He argued that the APELA was not an election protest but a "PEOPLE'S INITIATIVE" in the exercise of sovereign rights, and an exercise of the people's right to information on matters of public concern. He submitted an Addendum dated June 20, 2022 offering to shoulder all costs for the manual recount and requesting the opening of ballot boxes, auditing of SD cards by independent IT professionals, and the tambiolo system for Random Manual Audit selection. On June 30, 2022, he submitted a Manifestation with Urgent Request seeking an opportunity to present video presentations and accompanying evidence.

COMELEC's Law Department replied anew via a Letter dated July 7, 2022, noting the characterization of the APELA as a People's Initiative and citing COMELEC Resolution No. 10650 on the requirements for filing People's Initiative petitions. Petitioners treated this response as the final denial of their requests and, having received no further response to their June 30, 2022 Manifestation, filed the instant Petition for Certiorari and Mandamus directly with the Supreme Court, asserting that COMELEC's inaction amounted to grave abuse of discretion and denial of due process.

• Not an Election Protest: Petitioners maintained that the instant petition was not an electoral protest seeking to unseat any elected official, but an election controversy cognizable by COMELEC vindicating their rights of suffrage, to information, and to petition the government for redress of grievances as part of the collective popular sovereign.
• Non-Exclusive Remedies: Petitioners argued that COMELEC, in confusing their request as either an electoral protest or a petition for recall/initiative, failed to recognize that these remedies were not exclusive in vindicating their constitutional rights.
• No Compelling State Interest: Petitioners asserted that COMELEC had no compelling state interest in denying the requested recount, and that said denial violated their constitutional rights, with the burden of proving compelling state interest incumbent upon COMELEC.
• Class Suit: Petitioners contended the petition was a class suit of transcendental importance, with petitioners representing all voters in Pangasinan who were too numerous to join at present.
• Doubts on Election Results: Petitioners doubted the manner in which votes were counted by VCMs, citing the unusual speed of result transmission, high voter turnout in Pangasinan, and discrepancies with pre-election surveys.
• Social Media Evidence: Petitioners were alarmed by online opinions and observations from experts pointing to the statistical improbability of the election results, as summarized in an unsigned and unverified "Summary of Viral Social Media Postings."
• Inconclusive Random Manual Audit: Petitioners asserted that COMELEC's random manual audit was inconclusive since there was no indication that any precincts or VCMs from Pangasinan were subjected to said audit.
• Right of Suffrage: Petitioners grounded their request on their sovereign right of suffrage, which included the right to know how their votes were counted, tallied, and reported, and the corresponding obligation of COMELEC to accommodate their request to present testimonial, documentary, and video evidence.
• Statutory Basis: Petitioners cited the declaration of policy in Section 1 of Republic Act No. 8436 (as amended by Section 1 of Republic Act No. 9369) as sufficient to require and enable COMELEC to conduct the requested manual recount in the interest of transparency, accuracy, and truthfulness.
• Precedents: Petitioners cited Loong vs. Commission on Elections and Sandoval vs. Commission on Elections as upholding COMELEC's authority to revert to manual recounts when the automated election system fails and to correct manifest errors in certificates of canvass and election returns.
• No Adequate Remedy: Petitioners asserted they had no more plain, speedy, and adequate remedies in the ordinary course of law vis-à-vis COMELEC's inaction, which allegedly amounted to grave abuse of discretion.

• Defective Verifications: COMELEC argued that the petition suffered from defective verifications, as petitioners had no personal knowledge of the facts recited, their assertions being based on fears and speculations derived from hearsay opinions on social media whose authors were not joined in the proceedings and whose authenticity was not established.
• Mandamus Cannot Lie: COMELEC countered that mandamus could not lie because petitioners could point to no clear factual or legal basis for their right to a manual recount, and respondent could not be said to have reneged on its suffrage-related duties under the law.
• No Locus Standi: COMELEC argued that petitioners had no locus standi since they sustained no material injury, having all been able to cast their votes. It further argued the petition could not be a class suit since 32 petitioners from 9 cities and municipalities could not represent the entire class of 2,096,936 registered voters from all 48 cities and municipalities in Pangasinan.
• No Actual Case or Controversy: COMELEC asserted that the petition presented no actual case or controversy, as petitioners intended neither to nullify the elections nor unseat any official, and presented no concrete evidence of cheating or mass disenfranchisement — only bare assertions of lack of faith in VCMs based on conjectures and suspicions encountered online.

• Verification: Whether the verifications vis-à-vis the instant petition are defective.
• Locus Standi: Whether Legaspi, et al. have locus standi.
• Class Suit: Whether the instant petition can be classified as a class suit.
• Actual Case or Controversy: Whether there is an actual case or controversy here.
• Exhaustion of Administrative Remedies: Whether Legaspi, et al. exhausted all administrative remedies before resorting to the instant petition.
• Availability of Prerogative Writs: Whether certiorari or mandamus can lie.

• Verification: Yes, the verifications are defective. Petitioners lacked personal knowledge of the ultimate facts alleged, their knowledge being derived from mere information and belief based on news, social media, and unauthenticated online sources, rendering the petition treatable as an unsigned pleading.
• Locus Standi: No. Petitioners lacked locus standi as they suffered no concrete injury, their interest being merely general and shared by the entire voting population. No transcendental importance was demonstrated absent any present or imminent injury to fundamental rights.
• Class Suit: No. The petition could not be designated as a class suit because the APELA's signature pages were not submitted, precluding any determination of numerosity, representativeness, or authorization of the supposed class members.
• Actual Case or Controversy: No. There was no actual case or controversy because COMELEC never actually denied any proper request; its communications were merely guidance, and petitioners' own muddled terminology — designating the APELA as a "people's initiative" — caused the confusion.
• Exhaustion of Administrative Remedies: No. Petitioners failed to exhaust administrative remedies available under COMELEC's FOI Manual (Resolution No. 10685), which provides a complete procedure for requesting access to information and an administrative appeal process for denials.
• Availability of Prerogative Writs: No. Certiorari could not lie absent grave abuse of discretion, as COMELEC could not have gravely abused its discretion when it did not understand what relief petitioners sought. Mandamus could not issue absent a clear legal right to a manual recount, which exists neither in statute nor jurisprudence.

• Verification: Under Rule 7, Section 4 of the 2019 Rules of Court, a pleading is verified by an affidavit based on personal knowledge or authentic documents. Petitioners' verifications, while formally compliant word-for-word, were based on mere information and belief derived from social media, television, and COMELEC's website — not personal knowledge of the transmission of results, the observations of technical experts, or even their actual participation in signing the APELA (signature pages being absent). Citing Regalado's commentary and Altres vs. Empleo, the Court held that verification based on information and belief is insufficient; the purpose of verification is to forestall perjured or hearsay allegations. The Court applied the third guideline from Altres: verification is deemed substantially complied with when one who has ample knowledge swears to the truth of the allegations. Here, petitioners clearly did not have personal knowledge of the circumstances prompting their fears and speculations. Without personal knowledge or authenticated documents — not even the COMELEC communications (mere unauthenticated photocopies), the Judicial Affidavits (self-serving without evidentiary attachments), the "Summary of Viral Social Media Postings" (unsigned and merely an aggrupation of excerpts), or the APELA (unauthenticated photocopy of the first page without signature pages) — the petition could be treated as a dismissible unsigned pleading.

• Locus Standi: Locus standi requires a personal and substantial interest in the case such that the party has sustained or will sustain direct injury as a result of the governmental act challenged. Petitioners' status as voters was a general interest shared by the entire voting population, insufficient under Integrated Bar of the Phils. vs. Hon. Zamora. While the Court may relax standing requirements for issues of transcendental importance, a mere invocation of transcendental importance is not enough; there must be a clear and imminent threat to fundamental rights, as held in In the Matter of Save the SC Judicial Independence & Fiscal Autonomy Movement vs. Abolition of JDF & Reduction of Fiscal Autonomy. Petitioners pointed to no immediate danger beyond speculative fears of being governed by persons who may not be entitled to their positions. Under Francisco, Jr. vs. The House of Representatives, a citizen suitor must show direct and personal injury, not merely indefinite suffering. The Court found that whether the petition was granted or denied, petitioners remained unscathed in terms of their constitutional rights.

• Class Suit: Under Rule 3, Section 12, a class suit requires that the subject matter be of common interest to many persons so numerous that joinder is impracticable, and that the representatives be sufficiently numerous to fully protect the interests of all. Petitioners alleged representation of over 71,000 voters who signed the APELA, but failed to attach the signature pages. Without these, the Court could not determine whether the affected parties were so numerous as to be impracticable to join, or whether petitioners were sufficiently representative. Moreover, participation in a signature campaign does not automatically equate to participation in the present proceedings without sufficient authorization for their supposed representatives to litigate on their behalf.

• Actual Case or Controversy: An actual case or controversy requires a conflict of legal rights susceptible of judicial resolution — a real and substantial controversy, not a theoretical question, as held in Kilusang Mayo Uno vs. Hon. Aquino and Information Technology Foundation of the Philippines vs. Commission on Elections. Petitioners' right of suffrage remained intact, as they admitted to having voted without governmental impediment. The Court rejected the proposition that suffrage encompasses a right to a full manual recount of an entire province based on unsubstantiated surmises — such a right exists neither in statute nor jurisprudence, and recognizing it would constitute judicial legislation. Loong vs. Commission on Elections, cited by petitioners, was distinguished: it involved VCMs that could not read printed ballots due to a printing error, authorizing manual counting (not recounting) as the only way to count votes. No analogous failure was alleged here — no allegation that VCMs rejected ballots, that precincts failed to transmit results, or that any failure of elections occurred in Pangasinan. The old pre-proclamation procedure for correction of manifest errors under Section 15 of Republic Act No. 7166 was noted as rendered defunct by automated elections. COMELEC's communications did not constitute a denial of any right; they were merely guidance, and the confusion was largely attributable to petitioners' own muddled terminology in designating the APELA as a "people's initiative." Petitioners' right to petition for redress of grievances was not violated, as nothing prevented them from being heard. Their right to information on matters of public concern was the most appropriate anchor for the petition, but was never properly invoked: the APELA and subsequent letters contained no specific request for access to particular documents, only vague references to knowing how votes were counted.

• Exhaustion of Administrative Remedies: The doctrine of exhaustion of administrative remedies requires that when an administrative remedy is provided by law, relief must be sought by exhausting that remedy before judicial intervention, as articulated in Dimson (Manila), Inc. vs. Local Water Utilities Administration. COMELEC had promulgated Resolution No. 10685 adopting an FOI Manual with a comprehensive procedure for requesting access to information, including an administrative appeal process and a presumption in favor of disclosure. Petitioners never resorted to this process. The Court found none of the recognized exceptions to the doctrine (as enumerated in Maglalang vs. Philippine Amusement and Gaming Corp.) present. While Valmonte vs. Belmonte, Jr. previously treated FOI issues as purely legal questions exempting exhaustion, the Court now held that reasoning outdated because government agencies with FOI policies and manuals have competence to rule in the first instance on FOI requests, making such rulings no longer pure questions of law but mixed questions involving factual issues properly cognizable before agencies with FOI adjudication processes.

• Availability of Prerogative Writs: Certiorari requires grave abuse of discretion amounting to lack or excess of jurisdiction. COMELEC could not have committed grave abuse of discretion when it did not actually understand what proper relief petitioners were seeking, given their muddled terminology. The burden was on petitioners to prove grave abuse, which they failed to discharge. Mandamus requires a clear legal right to the thing demanded and a corresponding imperative duty of the respondent. No statutory basis exists for a full manual recount of provincial results of a national/local election; this right pertains only to losing candidates who have filed election protests. The declaration of policy in Republic Act No. 9369 cannot serve as basis for such action. Regarding FOI, while petitioners theoretically have a constitutional right to information, the vagueness and breadth of their requests, combined with their failure to exhaust administrative remedies, precluded mandamus. The Court further held that actions on FOI requests under agency FOI manuals — which involve determination of factual and legal aspects and provide internal appellate processes — are discretionary rather than ministerial, and are thus reviewable by appeal or certiorari rather than mandamus. The Court emphasized that this ruling should not be seen as an ultimate denial of petitioners' constitutional right to FOI; they may still avail of the remedies in COMELEC's FOI Manual.

• Verification Requirement — A pleading required to be verified must contain a verification based on personal knowledge or authentic documents, not mere information and belief. A verification that is formally compliant word-for-word with Rule 7, Section 4 but is based on facts derived from social media, news, and unauthenticated online sources is defective and may result in the pleading being treated as an unsigned pleading. The purpose of verification is to forestall perjured or hearsay allegations. Verification is deemed substantially complied with when one who has ample knowledge swears to the truth of the allegations in the petition, and when matters alleged have been made in good faith or are true and correct.

• Locus Standi — Legal standing requires a personal and substantial interest in the case such that the party has sustained or will sustain direct injury as a result of the governmental act challenged. A mere general interest shared by the whole citizenry is insufficient. While the Court may relax standing requirements for issues of transcendental importance, a mere invocation of transcendental importance is not enough; there must be a showing of a clear and imminent threat to fundamental rights, and that the issues must be settled early. A citizen suitor must show not only that the government act is invalid but also that he sustained or is in imminent danger of sustaining some direct injury as a result of its enforcement.

• Class Suit Requirements — Under Rule 3, Section 12, a class suit requires that the subject matter be of common interest to many persons so numerous that joinder is impracticable, and that the representatives be sufficiently numerous to fully protect the interests of all. Failure to submit the signature pages supporting the alleged class membership precludes a determination of numerosity and representativeness. Participation in a signature campaign does not automatically equate to participation in litigation without sufficient authorization for supposed representatives.

• Actual Case or Controversy — An actual case or controversy requires a conflict of legal rights susceptible of judicial resolution — a real and substantial controversy with definite and concrete issues involving legal relations of parties having adverse legal interests, not a theoretical question. Mere speculations and surmises relative to past or future violations of rights are insufficient for purposes of determining whether a case constitutes a justiciable controversy. Concrete proof of an initiating party's rights and violations (existing or impending) thereof must be attendant.

• Exhaustion of Administrative Remedies — When an administrative remedy is provided by law, relief must be sought by exhausting that remedy before judicial intervention. The existence of an FOI Manual with an administrative appeal process requires exhaustion before resort to the courts. FOI rulings by government agencies are no longer pure questions of law but now involve factual issues properly cognizable before agencies with FOI adjudication processes, especially if they are highly technical in nature.

• Mandamus and FOI — Mandamus requires a clear legal right to the thing demanded and a corresponding imperative duty. Actions on FOI requests under agency FOI manuals, which involve factual and legal determinations and provide internal appellate processes, are discretionary rather than ministerial, and are thus reviewable by appeal or certiorari rather than mandamus. A prior, specific demand for access to particular information is required; vague and overly broad references to documents cannot constitute a proper FOI request.

• Freedom of Information — The constitutional right to information on matters of public concern (Article III, Section 7) is self-executing and may be invoked without enabling legislation. The government agency having custody of the desired information bears the burden of showing that the information is not of public concern or is exempted by law. The duty to disclose information (mandatory, covering transactions involving public interest) should be differentiated from the duty to permit access (requires a prior request or demand, has a broader scope embracing any matter in official communications and public documents). No rigid test exists for determining whether information is of public concern; it is for the courts to determine on a case-by-case basis.

• "even if the verification portion of a pleading, just like Legaspi, et al here, is compliant word-for-word with the requirements of Rule 7, Section 4, said compliance will not save the fact that a pleader's personal knowledge is actually not based on personal knowledge or even on any authenticated documents." — This passage articulates the ratio decidendi on the verification issue: formal compliance with the Rules cannot cure a substantive lack of personal knowledge or authentic documentary support.

• "it is too much of a stretch for the Court to hold that the constitutional right of suffrage encompasses the supposed right of the sovereign electorate in a locality to have an entire election conducted thereat fully and manually recounted based on unsubstantiated surmises and unfounded conjectures that supposedly shadow the said election's conduct and results. This supposed right exists neither in the statute books nor in jurisprudence, and for the Court to recognize such right here would be a dangerous tread into the forbidden waters of judicial legislation." — This passage defines the outer limits of the constitutional right of suffrage in the context of automated elections and rejects judicial creation of a recount right.

• "the fact that COMELEC's FOI Manual provides for the constitution of an appeals and review committee to decide appeals from initial denials of FOI requests means that the administrative process as spelled out in the FOI manuals and procedures of government agencies like COMELEC have actually and already become discretionary in nature, and no longer purely ministerial." — This passage establishes a significant doctrinal shift: FOI adjudication under agency manuals is now discretionary, not ministerial, affecting the availability of mandamus as a remedy.

• "the duty to disclose information should be differentiated from the duty to permit access to information. There is no need to demand from the government agency disclosure of information as this is mandatory under the Constitution; failing that, legal remedies are available. On the other hand, the interested party must first request or even demand that he be allowed access to documents and papers in the particular agency." — This passage, quoting Chavez vs. National Housing Authority, restates the canonical distinction between mandatory disclosure and access upon demand, which is central to the FOI framework.

• Altres vs. Empleo, 594 Phil. 246 (2008) — Followed for the guideline that verification is deemed substantially complied with when one who has ample knowledge swears to the truth of the allegations in the petition. Applied to find petitioners' verifications defective for lack of personal knowledge.

• Integrated Bar of the Phils. vs. Hon. Zamora, 392 Phil. 618 (2000) — Followed for the definition of locus standi and the rule that a general interest shared by the whole citizenry is insufficient, while also affirming the Court's discretion to relax standing for transcendental importance. Applied to deny standing where petitioners suffered no concrete injury.

• Legaspi vs. Civil Service Commission, 234 Phil. 521 (1987) — Followed as the first FOI case decided under the 1987 Constitution, establishing that the constitutional FOI provision is self-executing, that the government agency bears the burden of showing information is not of public concern or is exempted, and that no rigid test exists for determining public concern. Applied to recognize petitioners' theoretical right to FOI while denying the remedy for failure to properly invoke it.

• Loong vs. Commission on Elections, 365 Phil. 386 (1999) — Distinguished. Petitioners cited it as authority for manual recount, but the Court held it involved manual counting (not recounting) necessitated by VCMs that could not read ballots due to a printing error — a circumstance not alleged or proven here.

• Chavez vs. Public Estates Authority (PEA), 433 Phil. 506 (2002) — Distinguished. Cited for recognition of locus standi based on transcendental importance in FOI cases, but distinguished as involving issues requiring immediate resolution with direct bearing on constitutional rights (ongoing renegotiations close to conclusion), unlike the speculative and non-urgent concerns here.

• Kilusang Mayo Uno vs. Hon. Aquino, 850 Phil. 1168 (2019) — Followed for the requirement of an actual case or controversy as an absolute necessity for the exercise of judicial review, defining it as a conflict of legal rights susceptible of judicial resolution.

• Guingona, Jr. vs. Commission on Elections, 634 Phil. 516 (2010) — Distinguished. Cited for the Court's order compelling COMELEC to explain its preparations for the 2010 automated elections, but distinguished by the urgency factor — the petition was filed two weeks before election day, making time of the essence and the case one of transcendental importance.

• Chavez vs. National Housing Authority, 557 Phil. 19 (2007) — Followed for the distinction between the duty to disclose information (mandatory, no need for demand) and the duty to permit access (requires prior request or demand), and for the observation that no enabling law yet provides mechanics for compulsory disclosure. Applied to find that petitioners made no proper FOI demand.

• Dimson (Manila), Inc. vs. Local Water Utilities Administration, 645 Phil. 309 (2010) — Followed for the doctrine of exhaustion of administrative remedies, requiring that when an administrative remedy is provided by law, relief must be sought by exhausting that remedy before judicial intervention.

• Valmonte vs. Belmonte, Jr., 252 Phil. 264 (1989) — Distinguished. Previously cited for the proposition that FOI issues are purely legal questions exempt from exhaustion of administrative remedies; the Court held this reasoning outdated because government agencies now have FOI policies and manuals with competence to rule in the first instance.

• Rule 7, Section 4, 2019 Rules of Court — Defines verification requirements: a pleading is verified by an affidavit alleging that the allegations are true and correct based on personal knowledge or authentic documents. Applied to find petitioners' verifications defective as based on mere information and belief from social media rather than personal knowledge or authenticated documents.

• Rule 3, Section 12, 2019 Rules of Court — Defines class suit requirements: when the subject matter is of common interest to many persons so numerous that joinder is impracticable, a sufficiently numerous number may sue or defend for the benefit of all. Applied to find the petition could not be designated as a class suit due to absence of the APELA's signature pages.

• Rule 65, Sections 1 and 3, Rules of Court — Govern petitions for certiorari (requiring grave abuse of discretion amounting to lack or excess of jurisdiction) and mandamus (requiring unlawful neglect of a duty specifically enjoined by law). Applied to find neither writ could issue: no grave abuse of discretion was shown, and no clear legal right to a manual recount exists.

• Article III, Section 7, 1987 Constitution — Guarantees the right of the people to information on matters of public concern and access to official records. Recognized as self-executing and the most appropriate constitutional anchor for petitioners' claims, but found not to have been properly invoked due to the absence of a specific and proper demand for access to particular documents.

• Article IX(C), Section 2(J), Constitution — Grants COMELEC broad power to enforce and administer all laws relative to the conduct of elections. Cited in Loong as basis for COMELEC's incidental powers, but distinguished as inapplicable here absent extraordinary circumstances equating to a failure of the counting and transmission of election results.

• Section 1, Republic Act No. 8436 (as amended by Section 1 of Republic Act No. 9369) — Declaration of policy on the automated election system, ensuring transparent and credible elections. Petitioners cited it as basis for manual recount, but the Court held it could not serve as statutory basis for such action; the proper forum for granting such a right to the public lies in Congress, not the courts.

• Section 29, Republic Act No. 8436 (as amended by Section 24 of Republic Act No. 9369) — Provides for random manual audit in one precinct per congressional district randomly chosen by COMELEC. The Court noted its limited scope, insufficient for the full provincial recount petitioners sought.

• COMELEC Resolution No. 10685 — COMELEC's FOI Manual adopted December 2020, providing a comprehensive procedure for requesting access to information, including an administrative appeal process for denials and a presumption in favor of disclosure. The Court held petitioners failed to exhaust remedies available thereunder, constituting a fatal lacuna in the petition.

• Republic Act No. 6735 (Initiative and Referendum Act) — Governs people's initiatives. The Court noted the APELA's designation as a "people's initiative" was clearly not contemplated under this law, and COMELEC could not be blamed for its puzzlement at the designation.

Gesmundo, C.J., Caguioa, Hernando, Inting, Zalameda, Lopez, Rosario, Lopez (J.), Dimaampao, Marquez, and Kho, Jr., JJ., concur. Leonen, SAJ, and Lazaro-Javier, JJ., filed separate concurring opinions. Singh, J., filed a concurring opinion. The texts of the separate concurring opinions are not included in the provided case text.