Facts:

Several petitions for certiorari and prohibition were filed challenging the constitutionality of
Executive Order No. 464 (E.O. 464), issued by the President on September 28, 2005. E.O.
464 required all heads of executive departments to secure the President's consent before
appearing before Congress. The controversy arose when the President's executive privilege
was invoked to prevent executive officials from attending a Senate hearing on the North
Luzon Railways Corporation project.

Issues:

Whether E.O. 464 infringes on Congress's power of inquiry.

Whether E.O. 464 violates the public's right to information on matters of public concern.
Ruling:
The petitions were partly granted.

The Court recognized executive privilege but emphasized that it must be clearly asserted
and validly invoked. E.O. 464's requirement for presidential consent for department heads to
appear in the "question hour" was deemed valid, as it aligns with the discretionary nature of
such appearances as per the Constitution. However, this requirement does not extend to
appearances in inquiries in aid of legislation. In such cases, Congress is not obliged to
respect the refusal of department heads to appear unless a valid claim of privilege is
subsequently made.

E.O. 464's implied claim of privilege was deemed invalid. Congress has the right to
information from the executive branch for legislative purposes, and any assertion of
privilege must be clearly stated with reasons provided. Thus, while the requirement for
presidential consent for the question hour was upheld, it cannot be applied to inquiries in aid
of legislation without a valid claim of privilege.

The Court affirmed Congress's power of inquiry and the public's right to information, striking
down the implied claim of privilege under E.O. 464. While department heads may require
presidential consent for the question hour, such requirement does not extend to legislative
inquiries unless a valid claim of privilege is asserted.