Case Digest (G.R. No. 184849)
Facts:
Spouses PNP Director Eliseo D. Dela Paz (Ret.) and Maria Fe C. Dela Paz v. Senate Committee on Foreign Relations and Senate Sergeant-at-Arms Jose Balajadia, Jr., G.R. No. 184849, February 13, 2009, Supreme Court En Banc, Nachura, J., writing for the Court.Petitioners Gen. (Ret.) Eliseo D. Dela Paz and Mrs. Maria Fe C. Dela Paz filed a petition for certiorari and prohibition under Rule 65 on October 28, 2008, assailing orders of the Senate Committee on Foreign Relations (the respondent Committee) — specifically its denial of their Challenge to Jurisdiction with Motion to Quash Subpoenae and Senator Miriam Defensor‑Santiago’s verbal command to the Senate Sergeant‑at‑Arms Jose Balajadia, Jr. to arrest them during the Committee hearing of October 23, 2008.
The events began when a Philippine PNP delegation, including Gen. Dela Paz as comptroller and special disbursing officer, traveled to the INTERPOL General Assembly in St. Petersburg in October 2008; Gen. Dela Paz was to retire on October 9, 2008. On October 11, 2008 he was detained at a Moscow airport for failing to declare 105,000 euros found in his luggage; another 45,000 euros was also found. The Russian authorities confiscated the euros and detained the delegation for questioning but later allowed their return to the Philippines.
Upon return, petitioners were served subpoenas by the respondent Committee for an inquiry scheduled October 23, 2008. Instead of attending, petitioners filed a Challenge to Jurisdiction with Motion to Quash Subpoena before the Committee; Senator Santiago defended the Committee’s jurisdiction and ordered Balajadia to arrest petitioners at the hearing. The petitioners contended the Committee lacked jurisdiction under paragraph 12, Section 13, Rule 10 of the Senate Rules because the matter did not involve state‑to‑state relations; they also argued the arrest warrant was invalid for lack of majority signatures and that the Senate rules relied upon had not been published as required by the Constitution.
The Committee filed its Comment on January 22, 2009. Subsequently, the Senate issued a formal written Order of arrest signed by ten senators and approved by the Senate President, and the Senate Rules were published in two newspapers on October 31, 2008. The arrest order ultimately was not executed: on November 15, 2008 Gen...(Subscriber-Only)
Issues:
- Is the petition justiciable — may the Supreme Court review the Senate Committee’s exercise of jurisdiction and internal orders under Rule 65?
- Did the Senate Committee on Foreign Relations exceed its jurisdiction or commit grave abuse of discretion in investigating the Moscow incident and ordering petitioners’ arrest?
- Were the arrest orders invalid because they lacked the required majority signatures and were based on Senate rules not pu...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)