Bengzon v. Senate Blue Ribbon Committee [G.R. No. 136760; July 29, 2003] FACTS:
Case concerns a petition for prohibition prohibition with prayer prayer for the issuance of a TRO and/or injunctive relief from the Senate Blue Ribbon Committee from requiring herein petitioners to testify and produce evidence related to the latter's inquiry on the sale of equity of Benjamin “Kokoy” Romualdez to the Lopa Group. The Republic of the Philippines, represented by the PCGG, filed with the Sandiganbayan a civil case against Benjamin Romualdez. The complaint alleged that Benjamin Romualdez Romualdez and Juliett Juliette e Gomez Romualdez, acting by themselves and/or in unlawful concert with then President Ferdinand Marcos and Imelda Marcos, and taking undue advantage of their relationship, influence and connection with the latt la tter er spo spouse uses, s, eng engage aged d in dev device ices, s, sc schem hemes es and st stra rata tagem gemss to unj unjust ustly ly enr enrich ich themselves at the expense of the Republic of the Philippines and the Filipino people. Confli Conf lict ctin ing g re repo port rtss on th the e di disp spos osit itio ion n by th the e PC PCGG GG of th the e Rom omua uald ldez ez corporations were carried in various newspapers. Other newspapers declared that shortly after the 1986 EDSA Revolution, the Romualdez companies were sold for P5 million, without PCGG approval, approval, to a holding company controlled by Romualdez, and that Ricardo Lopa, the President’s brother-in-law, had effectively taken over the firm.
In the Senate, Senator Enrile delivered a speech on the alleged take over by Lopa Lop a of SO SOLO LOIL IL Inc Incorp orpor orat ated, ed, the fla flagsh gship ip of the Fir First st Man Manil ila a Ma Manag nagem emen entt of Companies owned by Romualdez. Senator Enrile also called upon the Senate to look into the possible violation of the law, particularly with regard to RA 3019, The AntiGraft and Corrupt Practices Act. The matter was referred by the Senate to the Blue Ribbon Committee.
ISSUE: Whether or not the Senate Blue Ribbon Committee’s inquiry has valid legislative purpose as mandated by Art. VI, Sec. 21
HELD:
SC held that the Committee cannot require herein petitioners to participate
and answer questions as the law states tha officers can only be required to attend legislative inquiries if the purpose of such a session is to aid legislation, as stated in the Constitution. In this case, there is no suggestion of contemplated legislation; the purpose of said session is to find out whether or not violations were committed against RA 3019. In relation to the issue regarding separation of powers, the SC ruled that while it is true that each branch of governmenthas their own distinct set of roles and responsibilities, it does not follow that the distinction between these branches are intended for them to be absolutely unrestrained and independent of each other. The purpose of the principle of checks and balances is to ensure that no branch of government abuses its power and overrides another government. And since it is the mandate of the judicial body to review actual controversies, it is within its realm to review the issues arising from this said conflict, even if it concerns another body of government. The power to conduct formal inquiries or investigations is specifically provided in the Senate Rules of Procedure. Such inquiries may refer to the implementation or re-examination of any law or in connection with any proposed legislation or the formulation of future legislation. They may also extend to any and all matters vested by the Constitution in Congress and/or in the Senate alone. The speech of Senator Enrile contained no suggestion of contemplated legislation; he merely called upon the Senate to look into a possible violation of the Anti-Graft and Corrupt Practices Act. The purpose of the inquiry was to find out whether or not the relatives of President Aquino, particularly Lopa, had violated the law in connection with the alleged sale of 36 or 39 corporations belonging to Romualdez to the Lopa group. There appears to be, therefore, no intended legislation involved. This matter appears to be more within the province of the courts rather than of the legislature.
