Bengzon v Senate Blue Ribbon Committee Digest

G.R. No. 89914 November 20, 1991

Padilla, J.:

Facts:
1.  Petitioner was one of the defendants in a civil case filed by the government with the Sandiganbayan for
the alleged anomalous sale of Kokoy Romoaldez of several government corporations to the group of
Lopa,  a brother-in-law of Pres. Aquino.

2.       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."

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

4.        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: W/N the Blue Ribbon inquiry was in aid of legislation

NO.
1.          There appears to be 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 or not
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.  

2.       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.

3.         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.

4.          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.