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    Antolin v. Domondon

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    Vincent Catotal
    The Supreme Court granted Antolin's petition and remanded the case to the regional trial court for further proceedings. While national board examinations like the CPA exam involve matters of public concern regarding their fair administration, there may be valid reasons supported by law to limit public access to exam questions and answers. However, the Professional Regulation Commission, which promulgated the regulations limiting disclosure, was not a party to the case and did not provide justification for the confidentiality of exam documents. The high court determined all relevant issues must be addressed in the trial court before making a final ruling.

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    Antolin v. Domondon

    Uploaded by

    Vincent Catotal
    76 views1 page
    The Supreme Court granted Antolin's petition and remanded the case to the regional trial court for further proceedings. While national board examinations like the CPA exam involve matters of public concern regarding their fair administration, there may be valid reasons supported by law to limit public access to exam questions and answers. However, the Professional Regulation Commission, which promulgated the regulations limiting disclosure, was not a party to the case and did not provide justification for the confidentiality of exam documents. The high court determined all relevant issues must be addressed in the trial court before making a final ruling.

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    [03] Antolin v. Domondon

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    The Supreme Court granted Antolin's petition and remanded the case to the regional trial court for further proceedings. While national board examinations like the CPA exam involve matters of public concern regarding their fair administration, there may be valid reasons supported by law to limit public access to exam questions and answers. However, the Professional Regulation Commission, which promulgated the regulations limiting disclosure, was not a party to the case and did not provide justification for the confidentiality of exam documents. The high court determined all relevant issues must be addressed in the trial court before making a final ruling.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    76 views1 page

    Antolin v. Domondon

    Uploaded by

    Vincent Catotal
    The Supreme Court granted Antolin's petition and remanded the case to the regional trial court for further proceedings. While national board examinations like the CPA exam involve matters of public concern regarding their fair administration, there may be valid reasons supported by law to limit public access to exam questions and answers. However, the Professional Regulation Commission, which promulgated the regulations limiting disclosure, was not a party to the case and did not provide justification for the confidentiality of exam documents. The high court determined all relevant issues must be addressed in the trial court before making a final ruling.

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    © All Rights Reserved
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    ANTOLIN VS.

    DOMONDON (UP BOC 2018 Digest)


    G.R. No. 165036 and 175705 | July 5, 2010
    Political Law

    Facts: Petitioner Hazel Ma. C. Antolin took the October 1997 CPA Board Examinations but did not
    make it, failing four out of the seven subjects. Convinced that she deserved to pass, she wrote to
    respondent Abelardo T. Domondon, Acting Chairman of the Board of Accountancy, to furnish her a
    copy of her answer sheets as well as the questionnaires in all subjects with the corresponding answer
    keys. However, she was shown only her answer sheets. Respondent contends that Section 36 of
    Professional Regulation Commission (PRC) Resolution No. 332 and Section 20, Article IV of PRC
    Resolution No. 338 preclude the Board from releasing the Examination Papers (other than the answer
    sheet) and that the same constituted a valid limitation on petitioner’s right to information and access to
    government documents.

    Issue:
    1. WON petitioner Antolin has the right to demand access to the Examination Papers pursuant to her
    right to information as enshrined in the Constitution – YES.

    • The Court held that the right to information, like all the constitutional guarantees, is not absolute. The
    people's right to information is limited to "matters of public concern," and is further "subject to such
    limitations as may be provided by law." Similarly, a State's policy of full disclosure is limited to
    "transactions involving public interest," and is "subject to reasonable conditions prescribed by law."

    • The Court has always grappled with the meanings of the terms "public interest" and "public concern"
    which, as observed in Legaspi v. Civil Service Commission, are ultimately for the courts to determine
    on a case by case basis whether the matter at issue is of interest or importance, as it relates to or affects
    the public.

    • The Court concedes that national board examinations such as the CPA Board Exams are matters of
    public concern. The populace in general, and the examinees in particular, would understandably be
    interested in the fair and competent administration of these exams in order to ensure that only those
    qualified are admitted into the accounting profession.

    • On the other hand, there may be valid reasons to limit access to the Examination Papers in order to
    properly administer the exam. More than the mere convenience of the examiner, it may well be that
    there exist inherent difficulties in the preparation, generation, encoding, administration, and checking
    of these multiple-choice exams that require that the questions and answers remain confidential for a
    limited duration. However, the PRC is not a party to these proceedings. They have not been given an
    opportunity to explain the reasons behind their regulations or articulate the justification for keeping the
    Examination Documents confidential.

    • In view of the far-reaching implications of this case, which may impact on every board examination
    administered by the PRC, and in order that all relevant issues may be ventilated, we deem it best to
    remand these cases to the RTC for further proceedings.

    HELD: Petition granted. Case remanded to RTC for further proceedings.

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