L%mbino Vs.

Comelec
F%cts: Petitioners commenced g%thering sign%tures for %n initi%tive petition to ch%nge the 1987 constitution, they
filed % petition with the COMELEC to hold % plebiscite th%t will r%tify their initi%tive petition under RA 6735.
L%mbinoʼs group %lleged th%t the petition h%d the support of 6M individu%ls fulfilling wh%t w%s provided by Art. 17
of the Constitution. The proposed ch%nges will shift the present bic%mer%l-presidenti%l form of government to
unic%mer%l-p%rli%ment%ry. COMELEC denied the petition due to l%ck of en%bling l%w governing initi%tive petitions
%nd invoked the S%nti%go Vs. Comelec ruling th%t RA 6735 is in%dequ%te to implement the initi%tive petitions.

Issue:
W/N the L%mbino groupʼs initi%tive petition complies with Section 2, Article XVII of the Constitution on
%mendments to the Constitution through Peopleʼs Initi%tive.

Held: According to the SC the L%mbino group f%iled to comply with the b%sic requirements for conducting %
peopleʼs initi%tive.
!. The initi%tive petition does not comply with Section 2, Article XVII of the Constitution on direct propos%l by
the people. The petitioners f%iled to show th%t the initi%tive signer must be informed %t the time of the signing
of the n%ture %nd effect, f%ilure to do so is “deceptive %nd misle%ding” which renders the initi%tive void.
#. The initi%tive petition viol%tes Section 2, Article XVII of the Constitution dis%llowing revision through
initi%tives. The fr%mers of the constitution intended % cle%r distinction between “%mendment” %nd Peopleʼs
Initi%tive m%y propose only %mendments to the Constitution. Merging of the legisl%tive %nd the executive is %
r%dic%l ch%nge, therefore % constitutes % revision.

Aquino-Robredo vs. Comelec

F%cts:
!. Pres. Glori% M%c%p%g%l Arroyo signed R.A. 9716, which re%pportioned the (1st) %nd Second (2nd) Legisl%tive
Districts in the Province of C%m%rines Sur to cre%te %n %ddition%l legisl%tive district.
#. Sen. Aquino III %nd N%g% M%yor Robredo filed % petition for certior%ri %nd prohibition. Petitioners contend
th%t the re%pportionment introduced by Republic Act No. 9716, runs %foul of the explicit constitution%l
st%nd%rd th%t requires % minimum popul%tion of two hundred fifty thous%nd (250,000) for The petitioners
cl%im th%t the reconfigur%tion by Republic Act No. 9716 of the first %nd second districts of C%m%rines Sur is
unconstitution%l, bec%use the proposed first district will end up with % popul%tion of less th%n 250,000 or
only 176,383.

Issue: W/N RA 9716 w%s uncontitution%l.

Held: No. Section 5(3) of Art VI cle%rly distinguished % province from % city. Me%ning % province is %utom%tic%lly
entitled to one represent%tive while % city h%s to meet the 250,000 popul%tion requirement first. The Province of
C%m%rines Sur, with %n estim%ted popul%tion of 1,693,821 in 2007 is ─ b%sed on the formul% %nd const%nt
number of 250,000 used by the Constitution%l Commission in n%tion%lly %pportioning legisl%tive districts %mong
provinces %nd cities ─ entitled to two (2) districts in %ddition to the four (4) th%t it w%s given in the 1986
%pportionment. Popul%tion is not the only f%ctor but is just one of sever%l other f%ctors in the composition of the
%ddition%l district (i.e. Loc%l Govʼt Codeʼs requisite for cre%ting % province: not less th%n Php 20,000,000 %nnu%l
income, plus %t le%st 2,000 sq. m. OR %t le%st 250,000 inh%bit%nts).

M%ci%s vs. Comelec

F%cts:
!. Petitioners request th%t respondent offici%ls be presented from implementing RA 3040 th%t %pportions
represent%tive districts. They %lleged th%t s%id RA unconstitution%l %nd void bec%use: (%) it w%s p%ssed by
the House of Represent%tives without printed fin%l copies of the bill h%ving been furnished the Members %t
le%st three c%lend%r d%ys prior to its p%ss%ge; (b) it w%s %pproved more th%n three ye%rs %fter the return of
the l%st census of our popul%tion; %nd (c) it %pportioned districts without reg%rd to the number of inh%bit%nts
of the sever%l provinces.
ISSUES:
W/N RA 3040 viol%tes the principle of proportion%l represent%tive stipul%ted in the Constitution.

HELD : RA 3040 th%t g%ve provinces with less number of inh%bit%nts more represent%tive districts th%n those
with bigger popul%tion is decl%red inv%lid bec%use it viol%tes the principle of proportion%l represent%tion
prescribed by the Constitution. The Constitution directs th%t the one hundred twenty Members of the House of
Represent%tives "sh%ll be %pportioned %mong the sever%l provinces %s ne%rly %s m%y be %ccording to the
number of their respective inh%bit%nts."

Tor%ynovs. Comelec
F%cts:
!. Em%no w%s procl%imed governor of Mis%mis Orient%l. In his CoC, his residence w%s decl%red to be in
T%golo%n, MO. While still governor, Em%no executed % voter registr%tion record in CDO (geogr%phic%lly
loc%ted in MO) which he cl%imed 20 ye%rs of residence. He filed his CoC for m%yor of CDO, st%ting th%t his
residence for preceding 2 ye%rs %nd 5 months w%s in CDO.
#. Residents of CDO filed petition before COMELEC for disqu%lific%tion - f%ilire to meet the 1-ye%r residency
requirement.
e. Prior to resolution of petition, COMELEC procl%imed Em%no %s elected m%yor.
f. Petitioners filed petition for quo w%rr%nto before the COMELEC.

Issue:
W/N Em%no h%d duly est%blished his residence in CDO %t le%st one ye%r prior to the elections to qu%lify him to
run for the m%yorship
Held:
Em%no h%d %ctu%lly been residing in C%pistr%no subdivision, CDO, in % house he h%d bought in 1973. During the
three terms th%t he w%s governor of MO, he physic%lly lived in th%t city, where the se%t of the provinci%l
government w%s loc%ted. In June 1997, he %lso registered %s voter of the s%me city. CDO w%s once %n integr%l
p%rt of MO %nd rem%ins % geogr%phic%l p%rt of the province. Not only is it %t the center of the province: more
import%nt, it is itself the se%t of the provinci%l government. As % consequence, the provinci%l offici%ls who c%rry
out their functions in the city c%nnot %void residing therein much less, getting %cqu%inted with its concerns %nd
interests.

Osmen% vs. Pend%tun

!. Congressm%n Sergio Osmeñ% Jr., herein petitioner, delivered his privilege speech before the House m%king
serious imput%tions of bribery %g%inst the President of the Philippines. Bec%use of this, % Resolution w%s
issued %uthorizing the cre%tion of speci%l House Committee to investig%te the truth of the ch%rges m%de
%g%inst the President, to summon petitioner to subst%nti%te his ch%rges, %nd in c%se petitioner f%ils to do so,
to require petitioner to show c%use why he should not be punished by the House.
#. Petitioner then resorted to the Court seeking for the %nnulment of s%id resolution on the ground th%t it
infringes his constitution%l %bsolute p%rli%ment%ry immunity for speeches delivered in the House.
e. Me%nwhile, the Speci%l Committee continued with its proceeding, %nd %fter giving petitioner % ch%nce to
defend himself, found the l%tter guilty of seriously disorderly beh%vior. A House resolution w%s issued %nd
petitioner w%s suspended from office for 15 months.
f. There%fter, respondents filed their %nswer ch%llenging the jurisdiction of this Court to entert%in the petition,
%nd defended the power of Congress to discipline its members with suspension.

Issue:
W/N House Resolution viol%ted petitionerʼs constitution%lly gr%nted p%rli%ment%ry immunity for speeches
Held:
!. Section 15, Article VI of our Constitution provides th%t “for %ny speech or deb%te” in Congress, the Sen%tors
or Members of the House of Represent%tive “sh%ll not be questioned in %ny other pl%ce.” Our Constitution
enshrines p%rli%ment%ry immunity which is % fund%ment%l privilege cherished in every legisl%tive %ssembly of
the democr%tic world. It gu%r%ntees the legisl%tor complete freedom of expression without fe%r of being
m%de responsible in crimin%l or civil %ctions before the courts or %ny other forum outside of the
Congression%l H%ll. But it does not protect him from responsibility before the legisl%tive body itself whenever
his words %nd conduct %re considered by the l%tter disorderly or unbecoming % member thereof.

Ligot vs. M%th%y

FACTS: Ligot served %s % member of the House of Represent%tives of the Congress of the Philippines for three
consecutive four ye%r terms covering % twelve-ye%r sp%n from December 30, 1957 to December 30, 1969. During
his second term in office (1961-1965), RA 4134 “fixing the s%l%ries of constitution%l offici%ls %nd cert%in other
offici%ls of the n%tion%l government” w%s en%cted into l%w %nd thereof took effect on July 1, 1964. The s%l%ries of
members of Congress were incre%sed under s%id Act from P7,200.00 to P32,000.00 per %nnum, but the Act
expressly provided th%t s%id incre%ses “sh%ll t%ke effect in %ccord%nce with the provisions of the Constitution.”
Ligotʼs term expired on December 30, 1969, so he filed % cl%im for retirement under Commonwe%lth Act 186,
section 12 (c) %s %mended by RA 4968 which provided for retirement gr%tuity of %ny offici%l or employee,
%ppointive or elective, with % tot%l of %t le%st twenty ye%rs of service, the l%st three ye%rs of which %re continuous
on the b%sis therein provided “in c%se of employees b%sed on the highest r%te received %nd in c%se of elected
offici%ls on the r%tes of p%y %s provided by l%w.” HOR gr%nted his petition however, Vel%sco, the then Congress
Auditor refused to so issue certific%tion. The Auditor Gener%l then, M%th%y, %lso dis%llowed the s%me. The thrust
of Ligotʼs %ppe%l is th%t his cl%im for retirement gr%tuity computed on the b%sis of the incre%sed s%l%ry of
P32,000.00 per %nnum for members of Congress should not h%ve been dis%llowed, bec%use %t the time of his
retirement, the incre%sed s%l%ry for members of Congress “%s provided by l%w” (under Republic Act 4134) w%s
%lre%dy P32,000.00 per %nnum.
ISSUE:
Whether or not Ligot is entitled to such retirement benefit.
HELD:
To %llow petitioner % retirement gr%tuity computed on the b%sis of P32,000.00 per %nnum would be % subtle w%y
of incre%sing his compens%tion during his term of office %nd of %chieving indirectly wh%t he could not obt%in
directly. Ligotʼs cl%im c%nnot be sust%ined %s f%r %s he %nd other members of Congress simil%rly situ%ted whose
term of office ended on December 30, 1969 %re concerned for the simple re%son th%t % retirement gr%tuity or
benefit is % form of compens%tion within the purview of the Constitution%l provision limiting their compens%tion
%nd “other emoluments” to their s%l%ry %s provided by l%w. To gr%nt retirement gr%tuity to members of Congress
whose terms expired on December 30, 1969 computed on the b%sis of %n incre%sed s%l%ry of P32,000.00 per
%nnum (which they were prohibited by the Constitution from receiving during their term of office) would be to p%y
them prohibited emoluments which in effect incre%se the s%l%ry beyond th%t which they were permitted by the
Constitution to receive during their incumbency.

Bondoc vs. Pined%

F%cts:
!. In the elections held on M%y 11, 1987, M%rci%no Pined% of the LDP %nd Emigdio Bondoc of the NP were
c%ndid%tes for the position of Represent%tive for the Fourth District of P%mp%ng%. Pined% w%s procl%imed
winner. Bondoc filed % protest in the House of Represent%tives Elector%l Tribun%l (HRET), which is composed
of 9 members, 3 of whom %re Justices of the SC %nd the rem%ining 6 %re members of the House of
Represent%tives (5 members belong to the LDP %nd 1 member is from the NP). There%fter, % decision h%d
been re%ched in which Bondoc won over Pined%. Congressm%n C%m%sur% of the LDP voted with the SC
Justices %nd Congressm%n Cerilles of the NP to procl%im Bondoc the winner of the contest.
#. On the eve of the promulg%tion of the Bondoc decision, Congressm%n C%m%sur% received % letter informing
him th%t he w%s %lre%dy expelled from the LDP for %llegedly helping to org%nize the P%rtido Pilipino of
Edu%rdo Coju%ngco %nd for %llegedly inviting LDP members in D%v%o Del Sur to join s%id politic%l p%rty.
e. On the d%y of the promulg%tion of the decision, the Ch%irm%n of HRET received % letter informing the
Tribun%l th%t on the b%sis of the letter from the LDP, the House of Represent%tives decided to withdr%w the
nomin%tion %nd rescind the election of Congressm%n C%m%sur% to the HRET.

Issue: W/N the House of Represent%tives, %t the request of the domin%nt politic%l p%rty therein, m%y ch%nge th%t
p%rtyʼs represent%tion in the HRET to thw%rt the promulg%tion of % decision freely re%ched by the tribun%l in %n
election contest pending therein.

Held: The purpose of the constitution%l convention cre%ting the Elector%l Commission w%s to provide %n
independent %nd imp%rti%l tribun%l for the determin%tion of contests to legisl%tive office, devoid of p%rtis%n
consider%tion. As judges, the members of the tribun%l must be non-p%rtis%n. They must disch%rge their functions
with complete det%chment, imp%rti%lity %nd independence even independence from the politic%l p%rty to which
they belong. Hence, disloy%lty to p%rty %nd bre%ch of p%rty discipline %re not v%lid grounds for the expulsion of %
member of the tribun%l. In expelling Congressm%n C%m%sur% from the HRET for h%ving c%st % conscience vote ́ in
f%vor of Bondoc, b%sed strictly on the result of the ex%min%tion %nd %ppreci%tion of the b%llots %nd the recount of
the votes by the tribun%l, the House of Represent%tives committed % gr%ve %buse of discretion, %n injustice %nd %
viol%tion of the Constitution. Its resolution of expulsion %g%inst Congressm%n C%m%sur% is, therefore, null %nd
void.

Another re%son for the nullity of the expulsion resolution of the House of Represent%tives is th%t it viol%tes
Congressm%n C%m%sur%ʼs right to security of tenure. Members of the HRET, %s sole judge of congression%l
election contests, %re entitled to security of tenure just %s members of the Judici%ry enjoy security of tenure
under the Constitution. Therefore, membership in the HRET m%y not be termin%ted except for % just c%use, such
%s, the expir%tion of the memberʼs congression%l term of office, his de%th, perm%nent dis%bility, resign%tion from
the politic%l p%rty he represents in the tribun%l, form%l %ffili%tion with %nother politic%l p%rty or remov%l for other
v%lid c%use. A member m%y not be expelled by the House of Represent%tives for p%rty disloy%lty, short of proof
th%t he h%s form%lly %ffili%ted with %nother.

TIO vs VIDEOGRAM REGULATORY BOARD 151 SCRA 208

F%cts: The petition %ss%ils the constitution%lity of PD No. 1987 entitled “An Act Cre%ting the Videogr%m
Regul%tory Bo%rd” with bro%d powers to regul%te %nd supervise the videogr%m industry. Following its
promulg%tion is the %nnu%l t%x of 5% %nd 30% on gross receipts p%y%ble to the loc%l government.
The petitionerʼs grounds is th%t the imposition of t%x is % rider %nd is h%rsh %nd confisc%tory, oppressive %nd/or
unl%wful restr%int of tr%de.
It is %lso %lleged th%t the imposition of t%xes is inv%lid since the title of the bill s%id only for the cre%tion of the
Videogr%m Regul%tory Bo%rd, not for the imposition of t%xes.

Isse: W/N PD No. 1987 viol%tes the One-Subject-One-Title rule.

HELD: No. The constitution%l requirement th%t “Every Bill sh%ll be expressed in the title thereof” is sufficiently
complied with if the title is comprehensive enough to include the gener%l purpose which st%tute seeks to %chieve.
It is not necess%ry th%t the title express e%ch %nd every end th%t the st%ture wishes to %ccomplish. The
requirement is s%tisfied if %ll the p%rts of the st%tutes %re rel%ted %nd germ%ne to the subject m%tter expressed in
the title , or %s long %s they %re not inconsistent with or foreign with the gener%l subject %nd title.
In the c%se %t h%nd, the title m%y be re%d %s only for the cre%tion of the VRB, but the imposition of t%xes is %
direct consequence of the %ct, to perform its purpose to regul%te %nd r%tion%lize the heretofore uncontrolled
distribution of videogr%ms.

Philcons% vs. Enriquez

F"cts
!. The Gener%l Appropri%tions Act %ppropri%ted Php 86.3 billion for debt services. Congress %dded % speci%l
provision which provided th%t the %mount %ppropri%ted sh%ll be used for p%yment of the n%tion%l debt only
%nd not to be p%id to the li%bilities of the Centr%l B%nk. The %ppropri%tion for DPWH %lso provided th%t the
m%ximum %mount to be contr%cted for the m%inten%nce of n%tion%l ro%ds %nd bridges should not exceed
30% the %ppropri%tion for medicines by the Armed Forces of the Philippines required %pprov%l Congress for
the rele%se of funds.
#. In the Gener%l Appropri%tions Act of 1994 the %ppropri%tion for the Armed Forces of the Philippines cont%ins
% provision %uthorizing the Chief of St%ff to use s%vings in the %ppropri%tion to %ugment the pension %nd
gr%tuity fund of the Armed Forces of the Philippines. The President vetoed the %uthoriz%tion given by the
Chief of St%ff to use s%vings to %ugment the pension %nd gr%tuity fund. Sever%l Sen%tors questioned the
v%lidity of the veto.
Issue
W/N the Presidentʼs veto is v%lid.

Held: 
Petition dismissed. Congress c%n not include in the gener%l %ppropri%tions m%tters th%t should be en%cted in %
sep%r%te legisl%tion %nd if it does so, the in%ppropri%te provision must be tre%ted %s %n item %nd c%n be vetoed
by the President. The provision in GAA %uthorizing the Chief of St%ff to use s%vings to %ugment the pension %nd
gr%tuity fund viol%tes Section 25 (p%r%gr%ph 5) %nd Section 29 (p%r%gr%ph 1) of Article 6 of the 1987
Constitution. Only the President is %uthorized to %ugment items from s%vings in the gener%l %ppropri%tion to the
executive br%nch. Also pursu%nt to Section 29 – no money sh%ll be p%id out of the tre%sury except in pursu%nce
of %n %ppropri%tion m%de by l%w.

F%bi%n vs. Desierto

F%cts:
!. PROMAT p%rticip%ted in the bidding for government construction project including those under the FMED.
L%ter, misunderst%nding %nd unple%s%nt incidents developed between the p%rties. F%bi%n tried to termin%te
their rel%tionship but Agustin refused %nd resisted her %ttempts to do so to the extent of employing %cts of
h%r%ssment, intimid%tion %nd thre%ts. She eventu%lly filed the %forementioned %dministr%tive c%se %g%inst
him in % letter-compl%int d%ted July 24, 1995.
#. A compl%int sought the dismiss%l of Agustin for viol%tion of Section 19, R.A. No. 6770 (Ombudsm%n Act of
1989) %nd Section 36 of P.D. No. 807 (Civil Service Decree), with %n %ncill%ry pr%yer for his preventive
suspension. The c%se l%ter led to %n %ppe%l to the Ombudsm%n - who inhibited himself - %nd tr%nsferred the
c%se to the Deputy Ombudsm%n. The deputy ruled in f%vor of Agustin %nd in the order exoner%ted the priv%te
respondents from the %dministr%tive ch%rges.
e. F%bi%n elev%ted the c%se to the SC, %rguing th%t Section 27 of Republic Act No. 6770 (Ombudsm%n Act of
1989) th%t %ll %dministr%tive disciplin%ry c%ses, orders, directives or decisions of the Office of the
Ombudsm%n m%y be %ppe%led to the Supreme Court by filing % petition for certior%ri within ten (10) d%ys
from receipt of the written notice of the order, directive or decision or deni%l of the motion for reconsider%tion
in %ccord%nce with Rule 45 of the Rules of Court.

Issue
W/N %dministr%tive disciplin%ry c%ses, orders, directives or decisions of the Office of the Ombudsm%n m%y be
%ppe%led to the Supreme Court.

Held: No. Section 27 of Republic Act No. 6770 c%nnot v%lidly %uthorize %n %ppe%l to this Court from decisions of
the Office of the Ombudsm%n in %dministr%tive disciplin%ry c%ses. It consequently viol%tes the proscription in
Section 30, Article VI of the Constitution %g%inst % l%w which incre%ses the Appell%te jurisdiction of this Court. No
counterv%iling %rgument h%s been cogently presented to justify such disreg%rd of the constitution%l prohibition
which, %s correctly expl%ined in First Lep%rto Cer%mics, Inc. vs. The Court of Appe%ls, et %l. w%s intended to give
this Court % me%sure of control over c%ses pl%ced under its %ppell%te Jurisdiction. Otherwise, the indiscrimin%te
en%ctment of legisl%tion enl%rging its %ppell%te jurisdiction would unnecess%rily burden the Court.
T%n%d% vs. Tuver%
F%cts
Petitioners sought % writ of m%nd%mus to compel respondent public offici%ls to publish, %nd/or c%use the
public%tion in the Offici%l G%zette of v%rious presidenti%l decrees, letters of instructions, gener%l orders,
procl%m%tions, executive orders, letter of implement%tion %nd %dministr%tive orders, invoking the right to be
informed on m%tters of public concern %s recognized by the 1973 constitution.

Issue
W/N the public%tion of presidenti%l decrees, letters of instructions, gener%l orders, procl%m%tions, executive
orders, letter of implement%tion %nd %dministr%tive orders is necess%ry before its enforcement.

Held:
Article 2 of the Civil Code provides th%t “l%ws sh%ll t%ke effect %fter fifteen d%ys following the completion of their
public%tion in the Offici%l G%zette, unless it is otherwise provided ” The Court h%s ruled th%t public%tion in the
Offici%l G%zette is necess%ry in those c%ses where the legisl%tion itself does not provide for its effectivity d%te-for
then the d%te of public%tion is m%teri%l for determining its d%te of effectivity, which is the fifteenth d%y following
its public%tion-but not when the l%w itself provides for the d%te when it goes into effect. Article 2 does not
preclude the requirement of public%tion in the Offici%l G%zette, even if the l%w itself provides for the d%te of its
effectivity.
The public%tion of %ll presidenti%l issu%nces “of % public n%ture” or “of gener%l %pplic%bility” is m%nd%ted by l%w.
Obviously, presidenti%l decrees th%t provide for fines, forfeitures or pen%lties for their viol%tion or otherwise
impose % burden or. the people, such %s t%x %nd revenue me%sures, f%ll within this c%tegory. Other presidenti%l
issu%nces which %pply only to p%rticul%r persons or cl%ss of persons such %s %dministr%tive %nd executive orders
need not be published on the %ssumption th%t they h%ve been circul%rized to %ll concerned.
Public%tion is, therefore, m%nd%tory.
S%bio vs. Gordon
F%cts: Pursu%nt to Sen%te Resolution No. 455, Sen%tor Gordon requested PCGG Ch%irm%n S%bio %nd his
Commissioners to %ppe%r %s resource persons in the public meeting jointly conducted by the Committee on
Government Corpor%tions %nd Public Enterprises %nd Committee on Public Services. Ch%irm%n S%bio declined
the invit%tion bec%use of prior commitment, %nd %t the s%me time invoked Section 4(b) of EO No. 1: “No member
or st%ff of the Commission sh%ll be required to testify or produce evidence in %ny judici%l, legisl%tive or
%dministr%tive proceeding concerning m%tters within its offici%l cogniz%nce.”

Issue: W/N Section 4(b) of E.O. No.1 limits power of legisl%tive inquiry by exempting %ll PCGG members or st%ff
from testifying in legisl%tive proceeding.

Held: No. Article VI, Section 21 of the 1987 Constitution gr%nts the power of inquiry not only to the Sen%te %nd the
House of Represent%tives, but %lso to %ny of their respective committees. Cle%rly, there is % direct conferr%l of
investig%tory power to the committees %nd it me%ns th%t the mech%nism which the Houses c%n t%ke in order to
effectively perform its investig%tive functions %re %lso %v%il%ble to the committees. It c%n be s%id th%t the
Congressʼ power of inquiry h%s g%ined more solid existence %nd exp%nsive constru%l.  The Courtʼs high reg%rd to
such power is rendered more evident in Sen%te vs. Ermit%, where it c%tegoric%lly ruled th%t  “the power of inquiry
is bro%d enough to cover offici%ls of the executive br%nch.”  Verily, the Court reinforced the doctrine in Arn%ult
th%t “the oper%tion of government, being % legitim%te subject for legisl%tion,  is % proper subject for investig%tion”
%nd  th%t “the power of inquiry is co-extensive with the power to legisl%te”. Subject to re%son%ble conditions
prescribed by l%w, the St%te %dopts %nd implements % policy of full public disclosure of %ll its tr%ns%ctions
involving public interest.