Bengzon, Jr. vs.

Senate Blue Ribbon Committee

JOSE F.S. BENGZON JR., ABELARDO TERMULO, JOSEMANTECON, VICENTE

MILLS JR., LEONARDO GAMBOA, KURT BACHMANN JR., JOSE V.E.
JIMENEZ,ERNESTO CALUYA, AGERICO UNGSON, SUSAN ROXAS, ELVIE
CASTILLO, and CYNTHIA SABIDOLIMJAP, petitioners,
vs.
THE SENATE BLUE RIBBON COMMITTEE AND ITS MEMBERS, represented by and
through the CHAIRMAN, HON. WIGBERTO TAÑADA,respondents, JOSE S.
SANDEJAS, intervenor

FACTS:
Benjamin Romualdez, et al. were sued by PCGG in the Sandiganbayan for using
devices, plans, and strategies to unfairly benefit themselves at the expense of the
plaintiff and the Filipino people.The Senate Minority Floor Leader Enrile spoke before
the Senate on the alleged "takeover of SOLOIL Inc," the Flagship of the First Manila
Management of Companies or FMMC, by Ricardo Lopa. He urged the Senate to
investigate any potential legal violations with regard to RA 3019 (the Anti-Graft and
Corrupt Practices Act) in the case.
The Committee on Accountability of Public Officers (Senate Blue Ribbon
Committee, or SBRC), began its investigation into the situation. The SBRC has
summoned the petitioners and Ricardo Lopa to come before it and provide testimony
regarding what they know about the sale of 36 corporations that belonged to Benjamin
Romualdez. Invoking their right to due process and the possibility that their evidence
would unfairly harm the defendants and petitioners in the case before the
Sandiganbayan, Lopa and Bengzon declined to testify. The petitioner's request for a
testimony exemption was denied by the SBRC, and the agency carried on with its
inquiry. The petitioners requested a ban along with a TRO and/or injunctive relief,
saying that the SBRC exceeded its authority and legislative intent by requesting their
presence and testimony. In response to a move for reconsideration submitted by one of
the civil case's defendants, the Supreme Court took action.
ISSUES:
1. Whether or not the court has jurisdiction over the case.
2. Whether or not the SBRC's inquiry has valid legislative purpose.
3. whether or not the civil case of Sandiganbayan is beyond the power of the SBRC to
inquire into.
4. Whether or not the inquiry violates the petitioners' right to due process.

RULING:

1. Yes. In Angara v. Electoral Commission, the Constitution established a complex

structure of checks and balances to guarantee cooperation among the operations of the
many government departments. According to the Court, the judiciary is required by the
Constitution to exercise the function of defining constitutional bounds. Moreover, as held
in a recent case, "(t)he political question doctrine neither interposes an obstacle to
judicial determination of the rival claims. The jurisdiction to delimit constitutional
boundaries has been given to this Court. It cannot abdicate that obligation mandated by
the 1987 Constitution, although said provision by no means does away with the
applicability of the principle in appropriate cases." The Court is therefore of the
considered opinion that it has jurisdiction over the current dispute in order to ascertain
the nature and extent of the Senate Blue Ribbon Committee's authority to conduct
inquiries into personal matters in ostensible support of legislation.

2. No. Sec. 1 of the Senate Rules of Procedure Governing Inquiries in Aid of Legislation
expressly grants the authority to undertake formal inquiries or probes. Such inquiries
may be made in conjunction with the execution or review of any law, as well as any
proposed legislation or the creation of new laws. Additionally, they could apply to any
and all things that the Constitution has given sole authority to the Senate or to
Congress.Since the goal of the investigation is to determine whether or not the
President's relatives or Mr. Ricardo Lopa violated Section 5 of RA No. 3019, the "Anti-
Graft and Corrupt Practices Act," a matter that seems more to fall under the purview of
the courts than of the legislative branch, it appears that the respondent Committee's
proposed inquiry is not really "in aid of legislation" because it is not related to a purpose
within the jurisdiction of Congress.
3. No. Because Senator Enrile did not indict the PCGG and because Mr. Ricardo Lopa
and the petitioners in this case are not affiliated with the government but rather are
private citizens, it cannot be said that the investigation into the alleged sale of the 36 (or
39) corporations belonging to Benjamin "Kokoy" Romualdez to the Lopa Group will be
conducted in accordance with Senate Resolution No. 212.
4. Yes. The rights of those who appear in or are impacted by such inquiries shall be
respected, according to the Constitution. It should be underlined that the constitutional
constraint simply demands that the rights of individuals be maintained during the course
of the procedures, not that investigations into alleged violations of fundamental rights be
banned or forbidden. A witness cannot testify at all, according to the majority ruling, just
because he is already being prosecuted by the Sandiganbayan. In my opinion, the
Constitution does not permit someone to entirely refuse to testify, but rather to raise
objections whenever an accusatory question is asked or when he is required to expose
his legal defenses.