Case Digest (G.R. No. 89914)
Facts:
Jose F. S. Bengzon Jr., et al. v. The Senate Blue Ribbon Committee, G.R. No. 89914, November 20, 1991, the Supreme Court En Banc, Padilla, J., writing for the Court. Petitioners are private individuals (lawyers and corporate officers) impleaded as defendants in a Sandiganbayan civil action; respondents are the Senate Blue Ribbon Committee and its members, represented by Chairman Wigberto Tanada; Jose S. Sandejas appeared as intervenor.On July 30, 1987 the Republic, through the Presidential Commission on Good Government (PCGG) and assisted by the Solicitor General, filed Civil Case No. 0035 (PCGG Case No. 35) in the Sandiganbayan against Benjamin Romualdez and others for reconveyance, accounting and recovery of alleged ill-gotten assets; the Second Amended Complaint impleaded the present petitioners and alleged, inter alia, schemes involving the sale or concealment of interests in some 36–39 corporations and manipulation of corporate and financial arrangements. Petitioners filed their answers on September 28, 1988.
Public controversy followed and on September 13, 1988 Senator Juan Ponce Enrile delivered a privilege speech alleging a takeover of Romualdez firms by Ricardo Lopa and urged the Senate to investigate possible violations of R.A. No. 3019. The matter was referred to the Senate Blue Ribbon Committee, which subpoenaed petitioners and Mr. Lopa. At a hearing on May 23, 1989 Lopa declined to testify claiming it would prejudice the Sandiganbayan proceedings; petitioner Bengzon likewise refused, invoking due process and the risk that publicity and compelled testimony would prejudice their defense in Civil Case No. 0035.
The Committee suspended the hearing, required memoranda, and on June 5, 1989 issued a resolution rejecting the plea to be excused and voted to continue the inquiry. Claiming the Committee would exceed its jurisdiction and violate constitutional rights, petitioners filed a petition for prohibition with prayer for temporary restraining order / injunctive relief in the Supreme Court to enjoin the Committee from compelling their testimony and production of evidence. Jose S. Sandejas moved to intervene; the Court granted intervention and required the Committee to comment.
The Court first addressed whether it had jurisdiction to entertain the petition; it then considered whether the Committee’s inquiry was “in aid of legislation,” whether the subject was a purely private transaction beyond legislative competence, and whether compelling testimony would violate petitioners’ rights and intrude on the Sandiganbayan’s jurisdiction....(Subscriber-Only)
Issues:
- May the Supreme Court exercise jurisdiction to review and enjoin actions of the Senate Blue Ribbon Committee conducting an inquiry in aid of legislation?
- Was the Committee’s inquiry into the alleged sale of the Romualdez corporations properly “in aid of legislation”?
- Could the Committee, under the circumstances (pending Sandiganbayan Civil Case No. 0035 and petitioners’ rights), compel the petitioners to testify and produce evidence without violating constitutional rights or imp...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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