G.R. No. 240873 - Calida vs. Trillanes IV

Senator Antonio “Sonny” Trillanes IV
The Committee on Accountability of Public Officers and Investigations (Blue Ribbon Committee)
The Committee on Civil Service, Government Reorganization, and Professional Regulation

Alleged conflict of interest involving the award of government contracts to Vigilant Investigative and Security Agency, Inc.—a security services company owned by petitioner Calida and his family.
Petitioners contend that the investigation under Proposed Senate Resolution No. 760 is intended merely to target and humiliate them, rather than serve a bona fide legislative function.

Petitioners filed a Petition for Certiorari and Prohibition seeking a temporary restraining order and/or writ of preliminary injunction.
They also sought a permanent injunction to prohibit respondent Trillanes from conducting a legislative inquiry into their alleged conflict of interest.

On August 16, 2018, this Court directed respondent Trillanes to comment on the petition.
A Supplemental Petition was filed on August 31, 2018, impleading the Blue Ribbon Committee and the Committee on Civil Service.

Respondent Trillanes argued that the inquiry was conducted properly and in his official capacity.
He stressed that Proposed Senate Resolution No. 760 had undergone a first reading and formal referral by the Senate body, following proper Senate procedures, including a motion by Senator Miguel Zubiri to change the referral to the Blue Ribbon Committee.

Respondent Trillanes maintained that the inquiry was a legitimate legislative investigation.
He clarified that the initial hearing by the Committee on Civil Service was functus officio after the resolution’s referral changed, and that petitioners were only invited—not subpoenaed—to appear.

The investigation is claimed to be pursuant to Article VI, Section 21 of the 1987 Constitution, which authorizes the Senate or any House committee to conduct inquiries in aid of legislation.
Judicial precedents (e.g., Arnault v. Nazareno, Bengzon, Jr. v. Senate Blue Ribbon Committee, and Neri v. Senate Committee on Accountability of Public Officers and Investigations) elaborate on the scope and limitations of such inquiries.

Despite the constitutional provision, legislative inquiry must comply with the rules of procedure and not violate individual rights such as due process and the privilege against self-incrimination.
Inquiries solely intended to gather inculpatory evidence or to “punish” as opposed to informing legislation are deemed indefensible.

Proposed Senate Resolution No. 760 was filed during the second regular session of the 17th Congress, which closed on June 4, 2019.
The 18th Congress commenced on July 22, 2019, and the inquiry relevant to the petition ceased with the termination of the 17th Congress.

Respondent Trillanes had reached the end of his two-year Senate term, further contributing to the mootness of the petition.

Whether respondents—including Senator Trillanes and the involved Senate committees—should be enjoined from conducting legislative hearings in aid of legislation over Proposed Senate Resolution No. 760.

Whether the inquiry was properly authorized given that the Proposed Senate Resolution lacked clear legislative intent.
Whether respondent Trillanes acted beyond his authority by issuing invitations for the committee hearing.
Whether the investigation was aimed at targeting and humiliating petitioners rather than serving a legitimate legislative function.
Whether, given the cessation of the inquiry and the expiration of Senator Trillanes’ term, the case has become moot and is thereby not subject to judicial review.