G.R. No.

89914
Bengzon, Jr. vs. Senate Blue Ribbon Committee
November 20, 1991
PADILLA, J.

DOCTRINE:
Power of Congress to conduct inquiries in aid of legislation.—The 1987 Constitution expressly
recognizes the power of both houses of Congress to conduct inquiries in aid of legislation. xxx The power
of both houses of Congress to conduct inquiries in aid of legislation is not, xxx, absolute or unlimited. Its
exercise is circumscribed by the aforequoted provision of the Constitution. Thus, as provided therein, the
investigation must be “in aid of legislation in accordance with its duly published rules of procedure” and
that “the rights of persons appearing in or affected by such inquiries shall be respected”. It follows then
that the rights of persons under the Bill of Rights must be respected, including the right to due process
and the right not to be compelled to testify against one’s self.

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 than 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.

By virtue of a privilege speech made by Sen. Enrile urging the Senate to look into the transactions, an
investigation was conducted by the Senate Blue Ribbon Committee. Petitioners and Ricardo Lopa were
subpoenaed by the Committee to appear before it and testify on "what they know" regarding the "sale of
thirty-six (36) corporations belonging to Benjamin "Kokoy" Romualdez."

At the hearing, Lopa declined to testify on the ground that his testimony may "unduly prejudice" the
defendants in civil case before the Sandiganbayan.

Petitioner filed for a TRO and/or injunctive relief claiming that the inquiry was beyond the jurisdiction of
the Senate. He contended that the Senate Blue Ribbon Committee acted in excess of its jurisdiction and
legislative purpose. One of the defendants in the case before the Sandiganbayan, Sandejas, filed with the
Court of motion for intervention. The Court granted it and required the respondent Senate Blue Ribbon
Committee to comment on the petition in intervention.
ISSUE:
Whether the Senate Blue Ribbon Committee’s inquiry was in aid of legislation

RULING:
No. There is no intended legislation involved. The purpose of the inquiry to be conducted is not related to
a purpose within the jurisdiction of Congress, it was conducted to find out whether the relatives of
President Aquino, particularly Mr. Lopa had violated RA 3019 in connection with the alleged sale of the
36 or 39 corporations belonging to Benjamin "Kokoy" Romualdez to the Lopa Group.

The power of both houses of Congress to conduct inquiries in aid of legislation is not absolute or
unlimited. Its exercise is circumscribed by the Constitution. As provided therein, the investigation must
be "in aid of legislation in accordance with its duly published rules of procedure" and that "the rights of
persons appearing in or affected by such inquiries shall be respected." It follows then that the rights of
persons under the Bill of Rights must be respected, including the right to due process and the right not to
be compelled to testify against one's self.

Further, the civil case was already filed in the Sandiganbayan and for the Committee to probe and inquire
into the same justiciable controversy would be an encroachment into the exclusive domain of judicial
jurisdiction that had already earlier set in. The issue sought to be investigated has already been pre-
empted by the Sandiganbayan. To allow the inquiry to continue would not only pose the possibility of
conflicting judgments between the legislative committee and a judicial tribunal.

Finally, a congressional committee’s right to inquire is subject to all relevant limitations placed by the
Constitution on governmental action ‘including the relevant limitations of the Bill of Rights. One of these
rights is the right of an individual to against self-incrimination. The right to remain silent is extended to
respondents in administrative investigations but only if it partakes of the nature of a criminal proceeding
or analogous to a criminal proceeding.

Hence, the petitioners may not be compelled by respondent Committee to appear, testify and produce
evidence before it only because the inquiry is not in aid of legislation and if pursued would be violative of
the principle of separation of powers between the legislative and the judicial departments of the
government as ordained by the Constitution.