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CONSTITUTIONAL LAW I (Aids of Legislation) Case: Jose F.S. Bengzon V Senate Blue Ribbon Committee Facts

The Supreme Court granted the petition filed by Jose F.S. Bengzon against the Senate Blue Ribbon Committee. The Committee was investigating the alleged anomalous sale of corporations belonging to Benjamin "Kokoy" Romualdez to the group of Lopa, who was the brother-in-law of President Aquino. However, the Court found that the inquiry was not in aid of legislation as there was no intended legislation involved. Additionally, a civil case regarding the same issue was already pending in the Sandiganbayan, so the Committee's investigation would interfere with the judicial process and risk conflicting judgments. Thus, the Court concluded that the inquiry violated the separation of powers and Bengzon's right against self-incrimin

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35 views2 pages

CONSTITUTIONAL LAW I (Aids of Legislation) Case: Jose F.S. Bengzon V Senate Blue Ribbon Committee Facts

The Supreme Court granted the petition filed by Jose F.S. Bengzon against the Senate Blue Ribbon Committee. The Committee was investigating the alleged anomalous sale of corporations belonging to Benjamin "Kokoy" Romualdez to the group of Lopa, who was the brother-in-law of President Aquino. However, the Court found that the inquiry was not in aid of legislation as there was no intended legislation involved. Additionally, a civil case regarding the same issue was already pending in the Sandiganbayan, so the Committee's investigation would interfere with the judicial process and risk conflicting judgments. Thus, the Court concluded that the inquiry violated the separation of powers and Bengzon's right against self-incrimin

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CONSTITUTIONAL LAW I (Aids of Legislation)

CASE: JOSE F.S. BENGZON V SENATE BLUE RIBBON COMMITTEE

FACTS:

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.

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.

ISSUES

Whether or not the Senate Blue Ribbon Committee Inquiry was in aid of
legislation

HELD

(NO, Petition Granted)

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.

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.

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.

Article VI, Section 21


The Senate or the House of Representatives or any of its respective committee may conduct
inquiries in aid of legislation in accordance with its duly published rules of procedure. The rights
of persons appearing in or affected by such inquiries shall be respected.

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