Case Summary (G.R. No. 80447)
Key Dates and Prior Proceedings
• February 28–March 3, 1986: Alleged sale of 36–39 Romualdez-controlled corporations to PNI Holdings for ₱5 million
• July 30, 1987: PCGG files Sandiganbayan Civil Case No. 0035 against Benjamin “Kokoy” Romualdez et al., impleading petitioners
• 2–6 August 1988: Press reports on disposition of “Romualdez corporations”
• 13 September 1988: Senator Enrile delivers privilege speech urging inquiry into possible RA 3019 violations by President’s relatives
• 23 May 1989: Senate Blue Ribbon Committee hearing; petitioners and Lopa invoke due-process/self-incrimination rights and refuse to testify
• 5 June 1989: Committee resolution rejecting pleas and ordering continuation of inquiry
• 21 December 1989: Court grants intervention of Jose S. Sandejas
• November 20, 1991: Supreme Court issues decision
Applicable Constitutional and Statutory Provisions
• 1987 Constitution, Article VI, Section 21 – “inquiries in aid of legislation” must follow published rules and respect rights of persons appearing or affected
• Senate Rules of Procedure Governing Inquiries in Aid of Legislation (Sections 1 and 4)
• Bill of Rights, Article III, Section 17 – right against self-incrimination; Section 1, due-process guarantees
• Republic Act No. 3019, Section 5 – prohibition on certain relatives engaging in government business
Factual and Procedural Background
The PCGG, assisted by the Solicitor General, seeks recovery of alleged ill-gotten wealth from Romualdez-controlled enterprises through Sandiganbayan Civil Case No. 0035. The Second Amended Complaint charges, among other schemes, a March 3, 1986 “fictitious sale” of Romualdez corporate interests to PNI Holdings (linked to petitioners’ law firm and FMMC/PNI managers) to evade PCGG sequestration. While answers were on file in the Sandiganbayan, the Senate Blue Ribbon Committee—prompted by Senator Enrile’s privilege speech and a referral by Senator Mercado—subpoenaed petitioners to testify on the same transactions. Petitioners moved for prohibition, claiming no valid legislative purpose, pre-emption by the Sandiganbayan, and violation of due-process and self-incrimination rights.
Jurisdiction to Review Legislative Investigations
Respondents argued that separation of powers precludes judicial inquiry into legislative motives. The Court held that under Angara v. Electoral Commission and subsequent authority, it has the duty to delimit constitutional boundaries, including the extent of congressional investigative power, and may intervene when constitutional limitations are transgressed.
Scope and Limits of “In Aid of Legislation”
The 1987 Constitution expressly empowers either House or its committees to conduct inquiries in aid of legislation, subject to published procedural rules and respect for individual rights. An inquiry must be material or necessary to a power vested by the Constitution, determined by examining the speech or resolution authorizing it.
Lack of Valid Legislative Purpose
Senator Enrile’s speech sought merely “to look into” alleged RA 3019 violations by President’s relatives in connection with the sale of Romualdez corporations—without proposing or re-examining legislation. Senate Resolution No. 212, aimed at the PCGG’s performance, did not encompass the Enrile-triggered inquiry into private transactions by non-government actors. Thus the Committee’s investigation lacked the requisite legislative nexus.
Pre-emption by Judicial Proceedings
The same subject matter—the March 1986 sale and alleged concealment of Romualdez assets—was squarely before the Sandiganbayan, which had acquired jurisdiction upon filing of the Second Amended Complaint and answers by petitioners. Permitting concurrent legislative inqui
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Factual and Procedural Background
- In July 1987, the Republic of the Philippines, through the PCGG and Solicitor General, filed Civil Case No. 0035 before the Sandiganbayan for reconveyance, reversion, accounting, restitution, and damages against Benjamin “Kokoy” Romualdez and others, alleging schemes to unjustly enrich at public expense.
- Petitioners—lawyers and business managers—were impleaded as party defendants in the Second Amended Complaint, charged with assisting Romualdez in clandestine transactions involving some 36–39 corporations (e.g., manipulations of Erectors Inc., PCIB share assignments, sale of FMMC group firms for ₱5 million).
- In August–September 1988, press reports fueled controversy over the status of the “Romualdez firms,” including alleged secret sale to the Lopa Group and reported PCGG inaction.
- On September 13, 1988, Senate Minority Leader Enrile delivered a privilege speech urging inquiry into possible violations of R.A. 3019 by President Aquino’s relatives and associates (e.g., Ricardo Lopa) in connection with the Romualdez entities.
- The Blue Ribbon Committee, via Senate Resolution and referral by Senator Mercado, subpoenaed petitioners and Lopa to testify on May 23, 1989; Lopa declined, and petitioner Bengzon Jr. invoked due-process and privilege against self-incrimination.
- On June 5, 1989, the Committee rejected their plea, voted to continue the inquiry, and threatened further subpoenas.
- Petitioners filed a petition for prohibition with prayer for TRO/injunction, arguing lack of legislative purpose, invasion of purely private affairs, violation of due process, and no other adequate remedy.
- Intervenor Sandejas was permitted; the Committee filed comments contesting judicial interference, citing separation of powers and “in aid of legislation” jurisdiction.
- The Supreme Court en banc took cognizance of separation-of-powers doctrine (Angara v. Electoral Commission), the constitutional grant (Art. VI, Sec. 21, 1987 Constitution), and judicial review authority.
Issues Presented
- Does the Senate Blue Ribbon Committee’s inquiry into the alleged sale of Romualdez corporations serve a valid legislative purpose “in aid of legislation”?
- Is the transaction a “pure