By Louis ‘Barok‘ C. Biraogo — August 30, 2025
Introduction: A Citizen’s Crusade Crushed by Cowards in Robes
I’m Louis “Barok” Biraogo, the guy who’s been poking the bear of Philippine corruption since Aquino’s days. I’ve toppled commissions and challenged dynasties, but in Biraogo v. Martires (G.R. No. 254516), I aimed at Ombudsman Samuel Martires’ Memorandum Circular No. 1 (MC1), a slimy edict that locks Statements of Assets, Liabilities, and Net Worth (SALNs) behind a notarized consent wall, shielding systemic corruption from the public’s prying eyes.
My fight was simple: enforce the 1987 Constitution’s right to information (Art. III, Sec. 7) and accountability (Art. XI, Sec. 17). But the Supreme Court, in an 8-page resolution dated February 2021, didn’t just dismiss my petition—it smothered it in procedural quicksand so deep it could hide a dictator’s loot.
This isn’t a ruling; it’s a betrayal of every Filipino who dares demand the truth. The Court, meant to be our shield, became a lapdog for the corrupt elite.
The Court’s Procedural Circus: A Gutless Dodge of Justice
The Supreme Court didn’t engage with my case; it performed a procedural tap dance to avoid it. Their three excuses for dismissal are so flimsy they’d collapse under a stiff Manila breeze. Let’s shred them.
No Actual Case? More Like No Guts
The Court called my claims “bare, self-serving, and unsubstantiated” because I didn’t have a formal denial letter from Martires’ office. Are they serious? MC1 is the controversy, slapping a prior restraint on my constitutional right to check if officials are pocketing public funds. I pointed to the Ombudsman’s stonewalling—verbal rejections, ghosted requests, a system rigged to frustrate.
Yet, the Court, which bent over backwards in Chavez v. PCGG (G.R. No. 130716, 1998) to tackle “transcendental” issues, suddenly plays blind when Duterte’s allies are in the spotlight. Demanding a notarized rejection is like telling me to prove I’m drowning before tossing a rope. This isn’t law; it’s a judicial alibi.
Hierarchy of Courts? More Like Hierarchy of Hiding
The Court scolded me for going straight to them, insisting I start at a Regional Trial Court. Excuse me? This is a pure constitutional question: can Martires gut my rights with a memo? Forcing me to slog through lower courts, only to appeal back to the Supreme Court, is a bureaucratic hamster wheel designed to exhaust me while officials hide their wealth.
The Court’s own rules (Rule 65) allow direct petitions for grave issues, but when it’s the corrupt elite’s secrets at stake. This hierarchy nonsense is a dodge, plain and simple.
Unsubstantiated Claims? Try a Catch-22 Masterpiece
The Court blamed me for not proving denial, ignoring that MC1’s notarized consent rule ensures I’ll never get the rejection they demand. It’s a Catch-22 so twisted it could star in a Kafka reboot. The Philippine Center for Investigative Journalism (PCIJ) has been getting the same runaround since 2020, with SALN requests blocked left and right.
I’m not imagining this—Martires’ system is built to thwart scrutiny, then fault me for not having “evidence” of being thwarted. It’s like blaming a prisoner for not having the key. The Court’s not just wrong; it’s complicit in this transparency-killing scheme.
Duterte’s Shadow: The Court’s Complicity in a Cover-Up
This ruling isn’t a standalone flop—it’s part of Duterte’s secrecy empire. Since 2018, PCIJ has been denied Duterte’s SALNs, a stark break from past presidents’ openness. Martires, a Duterte appointee, didn’t stop at MC1; in 2021, he proposed jailing SALN commentators for up to five years, a move straight out of an authoritarian’s fever dream.
The Supreme Court’s refusal to touch MC1’s merits reeks of enabling a regime that thrives on opacity. I’ve seen this game before—my win in Biraogo v. Philippine Truth Commission (G.R. No. 192935, 2010) forced accountability on Aquino’s pet project. But now, with Duterte’s allies among the corrupt elite in the crosshairs, the Court’s too spineless to confront the entrenched rot festering across government. Smells like they’re shielding the corrupt elite’s dirty secrets, not defending the Filipino people’s right to know.
Constitutional Contortion: The Court’s Hypocrisy in High Definition
The irony is thicker than Manila’s traffic. This Court wielded its gavel like a guillotine to oust Chief Justice Sereno in Republic v. Sereno (G.R. No. 237428, 2018) for alleged SALN lapses in a politically charged quo warranto, yet when I challenge Martires’ unconstitutional SALN lockdown, they skulk behind ‘discretion’ and procedural hogwash. They’ve regulated their own SALNs sensibly In Re: Request for Copy of 2008 SALN of Justices (A.M. No. 09-8-6-SC, January 24, 2012), balancing transparency with safeguards.
So why roll over for the Ombudsman’s overreach? The Constitution screams for public access (Art. III, Sec. 7; Art. XI, Sec. 17), yet the Court treats it like a suggestion when Duterte’s allies and the corrupt elite might face scrutiny for their hidden wealth. This is hypocrisy in robes, a Court that swings hard against foes but whispers deference for friends.
A Nation Gutted: The Fallout of a Spineless Ruling
This decision isn’t just a slap to me—it’s a knife in the Philippines’ back. We’re rotting at 115th on Transparency International’s 2023 Corruption Perceptions Index, and MC1’s survival is a neon invite for more graft. SALNs nailed Marcos’ loot and Corona’s accounts; now, they’re locked away, letting dynasties stash billions while I, and you, get excuses.
Public trust? Already crumbling—only 24% of Filipinos trusted the government ‘a lot’ as recently as 2023 Southeast Asia Barometer, a trend this ruling has only deepened as the judiciary and Ombudsman shield Duterte’s allies and the corrupt elite. MC1 greenlights other agencies to hide behind “regulation,” gutting RA 6713 and the Constitution. Journalists like Rappler and PCIJ, already battered, hit a brick wall with MC1’s notarized consent nonsense, unlike the Court’s own sensible SALN access rules In Re: Request for Copy of 2008 SALN of Justices (A.M. No. 09-8-6-SC, January 24, 2012), leaving us blind to the corrupt elite’s looting of the public purse.
My Futile Fight: A Maze Built to Break Me
The Court’s left me with options so absurd they’re a cruel joke:
- Beg officials I’m investigating for notarized consent—like asking a thief to sign off on a warrant. Success rate? Zero.
- Refile in a lower court, wasting years in a system that’ll punt it back to the Supreme Court, probably after the crooks I’m chasing retire to their villas.
- Wait for a new Ombudsman, hoping a political appointee grows a spine—about as likely as Duterte baring his SALNs.
- Try an FOI request or push Congress to fix RA 6713, but with lawmakers cozying up to elites, that’s a fantasy.
Every path is a trap, keeping me running in circles while the powerful laugh.
Conclusion: A Court That’s Sold Its Soul
In Biraogo v. Philippine Truth Commission, I fought for a government of laws, not men, and won. Now, the Supreme Court’s proven me wrong. By hiding behind procedure, it didn’t just dismiss my case—it torched the Constitution’s promise of transparency.
I stood up for every Filipino who wants to know if their leaders are servants or thieves. The Court, meant to be our guardian, chose to be Martires’, Duterte’s and the corrupt elite’s shield. This isn’t justice; it’s surrender. The rule of law bleeds, and I’m left shouting: when will the Court fight for us, not against us?
Key Citations
- 1987 Philippine Constitution:
- Article III, Section 7 (Right to Information);
- Article XI, Section 17 (SALN Disclosure).
- Supreme Court Resolution in Biraogo v. Martires:
- Biraogo v. Martires (G.R. No. 254516)
- Abogado.com.ph Report, February 2021.
- Related Case Precedents:
- Chavez v. PCGG (G.R. No. 130716, 1998)
- Republic v. Sereno (G.R. No. 237428, 2018)
- In Re: Request for Copy of 2008 SALN of Justices (A.M. No. 09-8-6-SC, January 24, 2012)
- Biraogo v. Philippine Truth Commission (G.R. No. 192935, 2010)
- Statutory Law: Republic Act No. 6713 (Code of Conduct and Ethical Standards).
- Corruption and Trust Metrics:
- Media and Civil Society Reports:
- Freedom of Information: FOI Program

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