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Bengzon v. Senate Blue Ribbon Inquiry

The Senate Blue Ribbon Committee subpoenaed petitioners Bengzon and Lopa to testify regarding the sale of corporations belonging to Benjamin Romualdez, which was the subject of a case before the Sandiganbayan. Bengzon and Lopa refused to testify, claiming it would prejudice the defendants in the Sandiganbayan case. The Committee rejected their plea. The Supreme Court ruled that the Committee's inquiry was not validly in aid of legislation and would encroach on the judiciary's domain, as the same issues were already before the Sandiganbayan. The Committee cannot investigate matters exclusively within the judiciary's province.

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2K views2 pages

Bengzon v. Senate Blue Ribbon Inquiry

The Senate Blue Ribbon Committee subpoenaed petitioners Bengzon and Lopa to testify regarding the sale of corporations belonging to Benjamin Romualdez, which was the subject of a case before the Sandiganbayan. Bengzon and Lopa refused to testify, claiming it would prejudice the defendants in the Sandiganbayan case. The Committee rejected their plea. The Supreme Court ruled that the Committee's inquiry was not validly in aid of legislation and would encroach on the judiciary's domain, as the same issues were already before the Sandiganbayan. The Committee cannot investigate matters exclusively within the judiciary's province.

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Roward
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  • Constitutional Law Case Overview
  • Legal Judgment and Reasoning

ROWARD TUBOG JD -1

USJR-LAW SY: 2020-2021

SUBJECT: Constitutional Law 1


TOPIC: Questioned inquiry is not in aid of legislation
TITLE: Bengzon v. Senate Blue Ribbon
CITATION: G.R. No. 89914, November 20, 1991

FACTS:
The Presidential Commission on Good Government (PCGG) filed with the
Sandiganbayan against Benjamin Romualdez, et al for engaging in
devices, schemes and stratagems to unjustly enrich themselves at the
expense of plaintiff and the Filipino people. The Senate Minority Floor
Leader Enrile delivered a speech before the Senate on the alleged take-
over personal privilege before the Senate on the alleged "takeover of
SOLOIL Inc," the FlagShip of the First Manila Management of Companies
or FMMC by Ricardo Lopa and called upon the Senate to look into the
possible violation of the law in the case with regard to RA 3019 (Anti-
Graft and Corrupt Practices Act).
The Senate Blue Ribbon Committee (Committee on Accountability of
Public Officers [SBRC]) started its investigation on the matter. Petitioners
and Ricardo Lopa were subpoenaed by the SBRC to appear before it and
testify on what they know regarding the sale of 36 corporations
belonging to Benjamin Romualdez. Lopa and Bengzon refused to testify,
invoking their rights to due process, and that their testimony may unduly
prejudice the defendants and petitioners in case before the
Sandiganbayan. SBRC rejected the petitioner's plea to be excused from
testifying and the SBRC continued its investigation of the matter. The
petitioners filed for prohibition with a prayer for TRO and/or injunctive
relief, claiming that the SBRC in requiring their attendance and
testimony, acted in excess of its jurisdiction and legislative purpose.
The Supreme Court intervened upon a motion for reconsideration filed
by one of the defendants of the civil case.
ISSUE:
Whether or not the Senate Blue Ribbon Committee’s inquiry has valid
legislative purpose.
RULING:
This is not a valid inquiry in aid of legislation.
It appears, therefore, that the contemplated inquiry by respondent
Committee is not really "in aid of legislation" because it is not
related to a purpose within the jurisdiction of Congress, since the
aim of the investigation is to find out whether or not the relatives
of the President or Mr. Ricardo Lopa had violated Section 5 of RA
No. 3019, the "Anti-Graft and Corrupt Practices Act", a matter that
appears more within the province of the courts rather than of the
legislature. Besides, the Court may take judicial notice that Mr.
Ricardo Lopa died during the pendency of this case.

In fine, for the respondent Committee to probe and inquire into


the same justiciable controversy already before the
Sandiganbayan, would be an encroachment into the exclusive
domain of judicial jurisdiction that had much earlier set in.

In Baremblatt vs. United States, 21 it was held that:


"Broad as it is, the power is not, however, without limitations. Since
Congress may only investigate into those areas in which it may
potentially legislate or appropriate, it cannot inquire into matters
which are within the exclusive province of one of the other branches
of the government. Lacking the judicial power given to the Judiciary,
it cannot inquire into matters that are exclusively the concern of the
Judiciary. Neither can it supplant the Executive in what exclusively
belongs to the Executive. . . . ."

We hold that the questioned 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
government, ordained by the Constitution.

ROWARD TUBOG JD -1 USJR-LAW SY: 2020-2021 SUBJECT: Constitutional Law 1 TOPIC: Questioned inquiry is not in aid of legislat
It appears, therefore, that the contemplated inquiry by respondent Committee is not really "in aid of legislation" because it

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