Case Digest (G.R. No. 167173)
Facts:
Standard Chartered Bank (Philippine Branch), et al. v. Senate Committee on Banks, Financial Institutions and Currencies, G.R. No. 167173, December 27, 2007, Supreme Court En Banc, Nachura, J., writing for the Court. Petitioners are Standard Chartered Bank (SCB)-Philippines and twelve of its officers; respondent is the Senate Committee on Banks, Financial Institutions and Currencies, represented by its Chairperson, Senator Edgardo J. Angara.The controversy arose after a February 1, 2005 privilege speech by Senator Juan Ponce Enrile alleging that SCB-Philippines sold unregistered foreign securities and urging an inquiry. Senator Enrile had filed P.S. Resolution No. 166, which directed the Senate committee to investigate "in aid of legislation" the reported sale of unregistered, high‑risk securities and to consider remedial measures given alleged inadequacy of existing laws and regulatory action (including references to R.A. No. 8799 and R.A. No. 8791). The committee, through its chair, scheduled an initial hearing for February 28, 2005 and invited petitioners and other resource persons (including SEC and BSP officials) to attend and submit position papers.
At the February 28 hearing petitioners, through counsel, submitted an opening statement asserting pending criminal and civil actions concerning the same subject and protested disclosures of client account information; Senator Enrile moved for issuance of subpoenae and for the Bureau of Immigration and Deportation (BID) to issue hold‑departure orders (HDOs) or include names on the watchlist. The committee approved the motion and adjourned the hearing. Petitioners were later served with subpoenae for a March 15, 2005 hearing; they then filed a Petition for Prohibition (with prayer for TRO/injunction) in the Supreme Court on March 11, 2005 seeking to enjoin the committee from proceeding, to annul the subpoenas duces tecum and ad testificandum, and to prohibit imposition of HDOs or placement on the BID Watch List.
The Court denied petitioners’ prayer for a TRO by resolution dated March 14, 2005; the committee proceeded and, on March 15, held petitioners and their counsel in contempt and ordered six‑hour detention after petitioners accused the committee of conducting an inquiry "in aid of collection." Petitioners later moved for partial reconsideration and filed another Manifestation and Motion (June 21, 2006) seeking to enjoin submissio...(Pro-only)
Issues:
- Did the Senate Committee act without jurisdiction or with grave abuse of discretion by conducting an investigation already the subject of pending judicial and administrative proceedings?
- Was the committee’s investigation actually an inquiry "in aid of collection" (thus beyond legislative power) rather than in aid of legislation?
- Did compelling petitioners to attend and testify before the committee violate their constitutional rights against self‑incrimination, to privacy, and to travel?
- Was the committee’s exercise of contempt power and its request to the BID to inc...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)