Title
Calida vs. Trillanes IV
Case
G.R. No. 240873
Decision Date
Sep 3, 2019
Solicitor General Calida et al. sought to halt Senator Trillanes' legislative inquiry into alleged conflicts of interest involving their security firm. The Court dismissed the petition as moot due to the end of the 17th Congress and Trillanes' term.

Case Summary (G.R. No. 240873)

Procedural History

The petitioners filed a Petition for Certiorari and Prohibition alleging that Proposed Senate Resolution No. 760 lacks intent for legislation and merely calls for an investigation. They challenge Trillanes's actions, arguing that he issued invitations to resource persons without the Senate body's requisite approval and maintain that the inquiry is a targeted attack intended solely to humiliate them.

Respondent's Position

Senator Trillanes denied the accusations, asserting that the proposed resolution had been properly processed within the Senate, having been referred to the appropriate committees with authority. He highlighted that the hearing invitations issued were part of his official capacity. Furthermore, Trillanes contended that the investigation was formally assigned to the Blue Ribbon Committee, and therefore, the actions contested by petitioners were moot because they concerned a matter that was no longer active due to the expiration of the 17th Congress.

Nature of the Inquiry and Its Legislative Basis

The Court referred to Article VI, Section 21 of the 1987 Philippine Constitution, which allows legislative inquiries in aid of legislation. The Court asserted that while legislative inquiries are indispensable for informed law-making, they must adhere to procedural rules and respect individual rights contained within the Bill of Rights. The concept that legislative bodies cannot engage in law enforcement or criminal investigations was reiterated, confirming that inquiries are tightly constrained to furthering legislative purposes rather than collecting incriminating evidence.

Judicial Review and Justiciability

The Court emphasized that its judicial review is limited to actual cases with substantive controversies. A case becomes moot when no legal rights conflict remains. The decision detailed that the Senate's investigation regarding Proposed Senate Resolution No. 760 had become moot following th

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