Powers of Congress

Title: Bengzon v Senate Blue Ribbon Committee

Citation: G.R. No. 89914, November 20, 1991

Facts:
Petitioner was one of the defendants in a civil case filed by the government with the
Sandiganbayan for the alleged anomalous sale of Kokoy Romoaldez of several
government corporations to the group of Lopa, a brother-in-law of Pres. Aquino. By
virtue of a privilege speech made by Sen. Enrile urging the Senate to look into the
transactions, an investigation was conducted by the Senate Blue Ribbon Committee.
Petitioners and Ricardo Lopa were subpoenaed by the Committee to appear before it
and testify on "what they know" regarding the "sale of thirty-six (36) corporations
belonging to Benjamin "Kokoy" Romualdez. At the hearing, Lopa declined to testify
on the ground that his testimony may "unduly prejudice" the defendants in civil case
before the Sandiganbayan. Petitioner filed for a TRO and/or injunctive relief
claiming that the inquiry was beyond the jurisdiction of the Senate. He contended
that the Senate Blue Ribbon Committee acted in excess of its jurisdiction and
legislative purpose. One of the defendants in the case before the Sandiganbayan,
Sandejas, filed with the Court of motion for intervention. The Court granted it and
required the respondent Senate Blue Ribbon Committee to comment on the petition
in intervention.

Issue/s:
Whether or not the Blue Ribbon Committee was in aid of legislation.

Ruling:
No. There appears to be no intended legislation involved. The purpose of the inquiry
to be conducted is not related to a purpose within the jurisdiction of Congress, it was
conducted to find out whether or not the relatives of President Aquino, particularly
Mr. Lopa had violated RA 3019 in connection with the alleged sale of the 36 or 39
corporations belonging to Benjamin "Kokoy" Romualdez to the Lopa Group.

The power of both houses of Congress to conduct inquiries in aid of legislation is not
absolute or unlimited. Its exercise is circumscribed by the Constitution. As provided
therein, the investigation must be "in aid of legislation in accordance with its duly
published rules of procedure" and that "the rights of persons appearing in or affected
by such inquiries shall be respected." It follows then that the rights of persons under
the Bill of Rights must be respected, including the right to due process and the right
not to be compelled to testify against one's self.
The civil case was already filed in the Sandiganbayan and for the Committee to
probe and inquire into the same justiciable controversy would be an encroachment
into the exclusive domain of judicial jurisdiction that had already earlier set in. The
issue sought to be investigated has already been pre-empted by the Sandiganbayan.
To allow the inquiry to continue would not only pose the possibility of conflicting
judgments between the legislative committee and a judicial tribunal.

Finally, a congressional committee’s right to inquire is subject to all relevant

limitations placed by the Constitution on governmental action ‘including the relevant
limitations of the Bill of Rights. One of these rights is the right of an individual to
against self-incrimination. The right to remain silent is extended to respondents in
administrative investigations but only if it partakes of the nature of a criminal
proceeding or analogous to a criminal proceeding. Hence, the petitioners may not be
compelled by respondent Committee to appear, testify and produce evidence before it
only because the inquiry is not in aid of legislation and if pursued would be violative
of the principle of separation of powers between the legislative and the judicial
departments of the government as ordained by the Constitution.