G.R. No. 184849 - Spouses Dela Paz vs. Senate Committee on Foreign Relations

Petitioners: Spouses General (Ret.) Eliseo D. dela Paz and Maria Fe C. dela Paz.
Respondents: Senate Committee on Foreign Relations (chaired by Senator Miriam Defensor-Santiago) and Senate Sergeant-at-Arms Jose Balajadia, Jr.
Nature of the Relief Sought:

Petitioners sought to enjoin the Committee from further hearings involving them.
They also sought to enjoin respondent Balajadia from implementing a verbal order for their arrest.

On October 6, 2008, a Philippine delegation comprising eight senior PNP officers, including Gen. Dela Paz (then comptroller and special disbursing officer), traveled to Moscow to attend the 77th General Assembly Session of INTERPOL in St. Petersburg.
Gen. Dela Paz was scheduled to retire on October 9, 2008.

On October 11, 2008, while at the Moscow airport departure area, Gen. Dela Paz was apprehended by local authorities for failing to declare in writing a sum of 105,000 euros found in his luggage.
In addition, Gen. Dela Paz was found to have 45,000 euros in his possession.
Both Gen. Dela Paz and the delegation were detained briefly for questioning, and eventually, after several days and subsequent release, the Russian government confiscated the euros.

Gen. Dela Paz arrived in Manila on October 21, 2008, followed by his wife, Maria Fe.
Upon arrival, they were met with subpoenae issued earlier by the Senate Committee, compelling their presence for an investigation into the Moscow incident.

On October 23, 2008, during the first Senate committee hearing, petitioners filed a pleading titled “Challenge to Jurisdiction with Motion to Quash Subpoena.”
In response, Senator Santiago vigorously defended the Committee’s jurisdiction and verbally ordered Senate Sergeant-at-Arms, Balajadia, to arrest the petitioners.

Petitioners argued that the Committee lacked jurisdiction since the incident did not involve state-to-state relations as required by paragraph 12, Section 13, Rule 10 of the Senate Rules.

Alleged that, in issuing the warrant of arrest, the Senate Committee violated its own rules by not obtaining the required signatures from the majority of its members.
Claimed the Senate Rules were unlawfully implemented because they were never properly published as mandated by the Constitution.

The petition requested enjoining the Committee from conducting hearings involving the petitioners.
It also sought to stop Balajadia from enforcing the arrest order.

The Senate subsequently and properly formalized the arrest order in writing, including the necessary signatures, with the Senate President’s approval.
The legislative investigation was later carried out jointly by the Senate Committee on Foreign Relations and the Senate Committee on Accountability of Public Officers and Investigations (Blue Ribbon Committee).
During the November 15, 2008, hearing, Gen. Dela Paz voluntarily appeared before the Committee, nullifying the need for his arrest.
Furthermore, Senator Santiago granted Gen. Dela Paz’s motion to excuse the presence of Mrs. Dela Paz, effectively withdrawing the order for her arrest.

Whether the Senate Committee on Foreign Relations had proper jurisdiction to investigate the Moscow incident, given the contention that the matter did not involve state-to-state relations as stipulated by the Senate Rules.

Whether the order for arrest issued by the Committee (and later formalized) complied with the required procedural norms, including the proper signatures and publication of Senate Rules.

The extent to which the Constitution’s grant to each House of Congress to determine its own rules limits judicial intervention.
Whether challenges based on alleged noncompliance with Senate Rules constitute justiciable issues or fall within the ambit of political questions, thereby being beyond the Court’s review.