Title
Standard Chartered Bank vs. Senate Committee on Banks, Ficial Institutions, and Currencies
Case
G.R. No. 167173
Decision Date
Dec 27, 2007
A foreign bank challenges a Senate inquiry into alleged illegal securities sales, claiming jurisdictional overlap with pending court cases and constitutional rights violations. The Supreme Court upholds the Senate's authority, ruling the investigation was in aid of legislation, not collection, and justified the contempt citation.

Case Summary (G.R. No. 167173)

Relief Sought by Petitioners

Petitioners sought:

  1. A TRO restraining the committee from proceeding with its inquiry and from enforcing any hold-departure orders or watch list placements against them;
  2. Annulment of issued subpoenae ad testificandum and duces tecum;
  3. Prohibition against compelling SCB-Philippines officers to testify further.

Grounds Alleged: Jurisdiction and Abuse of Discretion

Petitioners alleged:
• Lack of jurisdiction and grave abuse of discretion because the inquiry duplicates pending criminal and civil actions concerning the same allegations of selling unregistered securities;
• Inquiry effectively “in aid of collection” rather than legislation, encroaching on judicial functions;
• Violation of due process, right against self-incrimination, right to privacy, and right to travel by compelling testimony and placing officers on the watch list;
• Disregard of the committee’s own procedural rules.

Distinction from Bengzon Precedent

The petitioners relied on Bengzon Jr. v. Senate Blue Ribbon Committee, which barred a legislative inquiry that was not “in aid of legislation.” The Supreme Court distinguished Bengzon, noting that in the present case P.S. Resolution No. 166 explicitly aimed to identify gaps in existing laws and propose remedial measures, fulfilling the constitutional requirement under Article VI, Section 21.

Legislative Inquiry Versus Judicial Proceedings

• The mere pendency of related criminal or civil cases does not bar a properly authorized legislative investigation.
• Legislative inquiries serve to gather information for policy-making and cannot be subordinated to judicial or administrative processes.
• Petitioners were invited as resource persons; they could assert specific privileges when testifying but could not wholly refuse to appear.

Exercise of Contempt and Compelled Attendance

• Congress and its committees possess inherent power to punish contempt and enforce attendance to preserve the effectiveness of legislative inquiry.
• The committee’s request that the Bureau of Immigration and Deportation place petitioners on a watch list to ensure their availability was reasonable and lawful; no court-issued hold-departure orders were employed.

Privacy and Self-Incrimination Considerations

• The public interest in effective regulation of banking and securities transactions justified the limited intrusion on privacy; disclosure requirements met the rational-basis test under Morfe v. Mutuc.
• Petitioners, as

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