Bengzon v.

Blue Ribbon
FACTS:
On 30 July 1987, the Republic of the Philippines, represented by the Presidential Commission on Good
Governance (PCGG), filed a complaint with Sandiganbayan against the petitioners of this case. PCGG
allege, among others, that: defendants (petitioners therein) Benjamin Kokoy Romualdez and Juliette.
Gomez Romualdez, alleged cronies of former President Marcos and First Lady Imelda Romualdez
Marcos, engaged in schemes and stratagems to unjustly enrich themselves at the expense of the Filipino
people. Among these stratagems are (1) obtained control of some big business enterprises such as
MERALCO, Pilipinas Shell, and PCI Bank, (2) manipulated the formation of Erectors Holding Inc, to
appear viable and borrow more capital, reaching a total of more that P2 billion, (3) collaborated with
lawyers (petitioners therein) of the Bengzon Law Offices in concealing funds and properties, in
maneuvering the purported sale of interests in certain corporations, in misusing the Meralco Pension
Fund worth P25 million, and in cleverly hiding behind the veil of corporate entity. On 13 September 1988,
Sen. Juan Ponce Enrile delivered a speech before the Senate on the alleged take-over of SolOil
Incorporated by Ricardo Lopa (who died during the pendency of this case) and called upon the senate to
look into possible violation of the Anti Graft and Corrupt Practices Act or RA 3019. The Senate Committee
on Accountability of Public Officers or Blue Ribbon Committee (SBRC) started its investigation through a
hearing on 23 May 1989, but Lopa and Bengzon declined to testify. The SBRC rejected petitioner
Bengzon s plea and voted to pursue its investigation. Petitioner claims that the SBRC, in requiring their
attendance and testimony, acted in excess of its jurisdiction and legislative purpose. Hence this petition.
ISSUES:
1. WON the court has jurisdiction over this case.
2. WON the SBRC s inquiry has a valid legislative purpose.
3. WON the sale or disposition of the Romualdez corporations is a purely private transaction which is
beyond the power of the SBRC to inquire into.
4. WON the inquiry violates the petitioners right to due process.
HELD:
1. YES. As the court held in Angara vs. Electoral Commission, the Constitution provided for an elaborate
system of checks and balances to secure coordination in the workings of the departments of the
government, and it is the judiciary that was vested of the powers to determine the scope, nature and
extent of such powers.
2. NO. The speech of Sen. Enrile contained no suggestion on contemplated legislation; he merely called
upon the Senate to look into a possible violation of Sec. 5 of RA 3019. The purpose of the inquiry to be
conducted by respondent SBRC was to find out WON the relatives of President Aquino, particularly
Ricardo Lopa, had violated the law in connection with the alleged sale of the 36/39 corporations of Kokoy
Romualdez to the Lopa Group. There appears, therefore, no intended legislation involved. The inquiry
also is not conducted pursuant to Senate Resolution No. 2123 (SR 2123), as the committee alleges. The
inquiry under SR 2123 is to look into the charges against PCGG filed by stockholders of Oriental
Petroleum in connection with the implementation of Section 26 Article XVIII of the Constitution.
3. YES. Mr. Lopa and the petitioners are not connected with the government and did their acts as private
citizens, hence such a case of alleged graft and corruption is within the jurisdiction, not of the SBRC, but
of the courts. Sandiganbayan already took jurisdiction of this issue before the SBRC did. The inquiry of
the respondent committee into the same justiciable controversy already before the Sandiganbayan would

be an encroachment of into the exclusive domain of judicial jurisdiction.

4. NO. The Constitution provides the right of an accused of a crime to remain silent; this extends also to
respondents in administrative investigation but only if they partake of the nature of a criminal proceeding.
This is not so in this case. BUT since the court already held that the inquiry is not in aid of legislation, the
petitioners therein cannot be compelled to testify

Juan Pons and Gabino Beliso were trading partners. On April 5, 1914, the steamer Lopez y
Lopez arrived in Manila from Spain and it contained 25 barrels of wine. The said barrels of
wine were delivered to Beliso. Beliso subsequently delivered 5 barrels to Pons house. On
the other hand, the customs authorities noticed that the said 25 barrels listed as wine on
record were not delivered to any listed merchant (Beliso not being one). And so the customs
officers conducted an investigation thereby discovering that the 25 barrels of wine actually
contained tins of opium. Since the act of trading and dealing opium is against Act No. 2381,
Pons and Beliso were charged for illegally and fraudulently importing and introducing such
contraband material to the Philippines. Pons appealed the sentence arguing that Act 2381
was approved while the Philippine Commission (Congress) was not in session. He said that
his witnesses claim that the said law was passed/approved on 01 March 1914 while the
special session of the Commission was adjourned at 12MN on February 28, 1914. Since
this is the case, Act 2381 should be null and void.
ISSUE: Whether or not the SC must go beyond the recitals of the Journals to determine if
Act 2381 was indeed made a law on February 28, 1914.
HELD: The SC looked into the Journals to ascertain the date of adjournment but the SC
refused to go beyond the recitals in the legislative Journals. The said Journals are
conclusive on the Court and to inquire into the veracity of the journals of the Philippine
Legislature, when they are, as the SC have said, clear and explicit, would be to violate both
the letter and the spirit of the organic laws by which the Philippine Government was brought
into existence, to invade a coordinate and independent department of the Government, and
to interfere with the legitimate powers and functions of the Legislature. Pons witnesses
cannot be given due weight against the conclusiveness of the Journals which is an act of
the legislature. The journals say that the Legislature adjourned at 12 midnight on February
28, 1914. This settles the question, and the court did not err in declining to go beyond these
journals. The SC passed upon the conclusiveness of the enrolled bill in this particular case.