Case Digest (G.R. No. 89914) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose F.S. Bengzon, Jr. et al. vs. Senate Blue Ribbon Committee, G.R. No. 89914, decided on November 20, 1991 under the 1987 Constitution, petitioners Jose F.S. Bengzon, Jr., Abelardo Termulo, Jose Mantecon, Vicente Mills, Jr., Leonardo Gamboa, Kurt Bachmann, Jr., Jose V.E. Jimenez, Ernesto Caluya, Agerico Ungson, Susan Roxas, Elvie Castillo, and Cynthia Sabido Limjap (hereafter “petitioners”) sought a writ of prohibition to enjoin the respondent Senate Blue Ribbon Committee, chaired by Hon. Wigberto Tanada, from compelling their testimony and production of evidence in its inquiry into the alleged sale of thirty-six or thirty-nine corporations owned by Benjamin “Kokoy” Romualdez to the Lopa Group. The Presidential Commission on Good Government (PCGG), represented by the Solicitor General, had earlier filed Civil Case No. 0035 in the Sandiganbayan on July 30, 1987, for reconveyance, reversion, accounting, restitution, and damages, naming the petitioners as party defendants in i Case Digest (G.R. No. 89914) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- PCGG Civil Case No. 0035 before the Sandiganbayan
- On July 30, 1987, the Presidential Commission on Good Government (PCGG), represented by the Solicitor General, filed a complaint against Benjamin “Kokoy” Romualdez et al. for reconveyance, accounting, restitution, and damages.
- Under the Second Amended Complaint, petitioners (including lawyers and senior managers) were impleaded as defendants accused of collaborating in schemes to unjustly enrich themselves through the sale or concealment of 36–39 corporations tied to Romualdez.
- On September 28, 1988, petitioners filed their respective answers joining issues in the Sandiganbayan case.
- Senate Blue Ribbon Committee inquiry
- On September 13, 1988, Senator Juan Ponce Enrile delivered a privilege speech alleging the takeover of SOLOIL and other corporations by Ricardo Lopa (a relative of the President) and possible violations of Republic Act No. 3019.
- The matter was referred to the Senate Committee on Accountability of Public Officers (Blue Ribbon Committee), which subpoenaed petitioners and Lopa to testify on the “sale” of Romualdez corporations.
- At the May 23, 1989 hearing, Lopa and petitioner Bengzon Jr. invoked non-self-incrimination and due process, declined to testify; the Committee rejected their plea on June 5, 1989, and voted to continue the inquiry.
- Petition for prohibition before the Supreme Court
- Claiming the inquiry had no valid legislative purpose, encroached on pending Sandiganbayan proceedings, and violated their constitutional rights, petitioners sought prohibition and injunctive relief.
- Jose S. Sandejas intervened; the Senate Committee filed a comment asserting separation-of-powers immunity from judicial restraint.
Issues:
- Jurisdictional
- Does the Supreme Court have authority to enjoin a Senate inquiry in aid of legislation?
- Merits of inquiry
- Is the Blue Ribbon Committee’s investigation truly “in aid of legislation”?
- Does the inquiry usurp matters already before the Sandiganbayan?
- Does compelling petitioners to testify violate their rights to due process and against self-incrimination?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)