Case Summary (G.R. No. 184849)
Factual Background
On October 11, 2008, General Dela Paz was apprehended at a Moscow airport for failing to declare a substantial amount of cash amounting to 105,000 euros along with an additional 45,000 euros found in his possession. Following this incident, both petitioners were detained for questioning and subsequently returned to the Philippines, where they were issued subpoenae by the respondent Senate Committee for a hearing scheduled on October 23, 2008.
Petition for Certiorari and Prohibition
On October 28, 2008, the petitioners filed a Petition for Certiorari and Prohibition under Rule 65 of the Rules of Court, challenging the jurisdiction of the Senate Committee and seeking to quash the subpoenas issued against them. They contended that the Committee was acting outside its jurisdiction regarding the Moscow incident and alleged violations of Senate Rules in issuing an order for their arrest.
Jurisdictional Challenges
The petitioners argued that the respondent Committee lacked jurisdiction to investigate the matter since the Moscow incident did not pertain to state-to-state relations as stipulated in the Senate Rules. They also claimed that the arrest order was invalid due to improper issuance without requisite signatures from a majority of the Committee members and asserted that the Senate Rules were not published in accordance with constitutional requirements.
Senate's Discretionary Authority
The Court noted that Article VI, Section 16(3) of the 1987 Philippine Constitution grants each House of Congress the authority to determine its own rules of proceedings. This discretionary power encompasses the formulation and adoption of rules and is generally immune to judicial scrutiny unless there is clear evidence of arbitrary exercise leading to a denial of due process. The challenge presented by the petitioners was effectively deemed a political question beyond the jurisdiction of the Court.
Validity of the Committee's Jurisdiction
The Court found that the Senate Committee acted within its jurisdiction per the specific provisions of the Senate Rules, which encompass matters relating to the Philippines’ international obligations. The Moscow incident, involving a former high-ranking official and substantial public funds, had implications affecting the country’s international standing and compliance with treaties.
Joint Legislative Inquiry
The Court outlined that the inquiry was to also involve the Senate Committee on Accountability of Public Officers and Investigations (Blue Ribbon Committee), which is empowered to investigate matters of public interest, including potential misconduct by government officials. This corroborates that the investigation into General Dela Paz’s handling of public funds was indeed within the scope of Senate inquiry.
Legislative Orders and Publication of Rules
Post-incident, a formal order of arrest was executed following proper procedures, having multiple senato
...continue readingCase Syllabus (G.R. No. 184849)
Introduction
- The case involves a Petition for Certiorari and Prohibition filed under Rule 65 of the Rules of Court by petitioners General (Ret.) Eliseo D. Dela Paz and Mrs. Maria Fe C. Dela Paz.
- The petition was submitted on October 28, 2008, and challenges the actions of the Senate Foreign Relations Committee and its Chairperson, Senator Miriam Defensor-Santiago.
- The petitioners argue that the Senate Committee's orders were made with grave abuse of discretion and lack or excess of jurisdiction.
Factual Background
- On October 6, 2008, a Philippine delegation including Gen. Dela Paz traveled to Moscow for the 77th General Assembly Session of INTERPOL in St. Petersburg.
- Gen. Dela Paz, the comptroller and special disbursing officer of the PNP, was to retire on October 9, 2008.
- On October 11, 2008, he was detained at Moscow airport for not declaring €105,000 (approximately PHP 6,930,000) and for possessing an additional €45,000 (about PHP 2,970,000).
- The Russian government confiscated the euros and detained the delegation for questioning.
- After returning to the Philippines on October 21, 2008, the petitioners were issued subpoenas to attend a Senate hearing on October 23, 2008.
Legal Proceedings Initiated by Petitioners
- Instead of attending the hearing, the petitioners filed a "Challenge to Jurisdiction with Motion to Quash Subpoena" with the Senate Committee on Foreign Relations.
- Senator Santiago defended the Committee's jurisdiction and ordered the arrest of the petitioners.
Legal Arguments by Petitioners
- Petitioners conte