G.R. No. L-67181 - Nonato vs. Intermediate Appellate Court

On February 3, 1960, the Mayor of Manila issued an executive order creating an investigatory committee “to investigate the anomalies involving the license inspectors and other personnel of the License Inspection Division of the Office of the City Treasurer and of the License and Permits Division of this Office (of the Mayor).”
Mr. Jesus L. Carmelo was named chairman of this committee.

The committee issued subpoenas duces tecum to Armando Ramos, a private bookkeeper in Casa de Alba, requiring his appearance on June 3, 8, 9, 15, 16 and August 4, 11, 1960, in connection with an administrative case against Crisanto Estanislao. Ramos was duly served but refused to appear.
Petitioner-chairman filed in the Court of First Instance of Manila a petition to declare Ramos in contempt for his refusal, alleging obstruction of administrative proceedings. After hearing, the trial court dismissed the petition, holding (a) no law empowers mayoral committees to issue subpoenas or administer oaths, and (b) compelling Ramos to testify would violate his right against self-incrimination. Ramos had previously admitted to city investigators that he had misappropriated sums meant for the payment of taxes between 1956–1959.

Whether a committee created by the Mayor of Manila has authority—either under Rule 64 of the Rules of Court, Section 580 of the Revised Administrative Code, or by implication—to administer oaths, subpoena witnesses, and seek contempt sanctions.
Whether the Mayor’s implied power to investigate city employees includes delegation of compulsory process to an investigatory committee.

Whether compelling Ramos to testify before the committee would violate his constitutional privilege against self-incrimination, given his prior admissions of estafa.