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Bengzon v.

Senate Blue Ribbon Committee


Jose F.S. Bengzon, Jr. et al. v. The Senate Blue Ribbon Committee and Issues:
members, represented by and through Taada (Sandejas as intervenor) 1. W/N the Court has jurisdiction over case
2. W/N SBRCs inquiry has no legislative purpose, or not done in the
Doctrine: Investigations in aid of legislation is subject to limitations. They aid of legislation
must be in aid of legislation and in the inquiry, rights of the persons 3. W/N sale of Romualdez corporations is a purely private transaction
appearing in or affected by such shall be respected. which is beyond the power of the courts
Keywords: legislative investigations of Senate/HoR; requisites 4. W/N the inquiry violates their rights to due process
Nature: petition for prohibition with prayer for issuance of TRO to enjoin
SBRC from requiring petitioners to testify and produce evidence as its Held:
inquiry into the alleged sale of equity of Romualdez to Lopa Group in 36 or 1. Yes. The Court has jurisdiction over the case.
39 corporations; granted 2. Yes. Inquiry has no legislative purpose
Date: November 20, 1991 3. Yes. It violates petitioners right to due process.
Ponente: J. Padilla
Ratio:
Facts: As held in Angara v. Electoral Commission, Constitution provides
Case filed before Sandiganbayan by Republic: Benjamin Romualdez for a system of checks and balances in the govt to secure
and Juliette Romualdez acted with concert with Ferdinand and Imelda coordination. There is judicial supremacy, which is the power of
Marcos, engaged in devices, schemes, and stratagems to unjustly judicial review. It has jurisdiction in the case for determining the
enrich themselves at the expense of the country and the Filipinos scope and extent of power o SBRC to conduct inquiries into private
(MERALCO, PCI Bank, Erectors Holdings, Inc., Bengzon Law Offices, affairs in purported aid of legislation
FMMC, etc.)
Senate minority floor leader Enrile delivered a speech before the
Power of houses of Congress to conduct inquiries in aid of
Senate on alleged take-over of SolOil Inc. by Lopa, flagship company
legislation is not unlimited. Requisites are:
of FMMC, and called upon Senate to look into possible violation of law
o Investigation must be in aid of legislation in accordance
in the case
with duly published rules of procedure
Matter was referred to Committee on Accountability of Public Officers
Investigation was not in aid of legislation because
(BLUE RIBBON COMMITTEE) and it started its investigation;
subpoenaed Lopa (may unduly prejudice defendants in case before speech of Enrile contained no suggestion of
Sandiganbayan) and Bengzon, Jr. (invoking right to due process) who contemplated legislation. He merely called upon
both declined to testify. Senate to investigate possible violation of law.
SBRC suspended inquiry and directed them to file memorandum but o Rights of persons appearing in or affected by such inquiries
the former denied memo and rejected plea to be excused from shall be respected
testifying
Claiming that SBRC acted in excess of jurisdiction and legislative Congressional committees right to inquire is subject to limitations
purpose and that there is no appeal nor any other plain, speedy, and placed by the Constitution, including the Bill of Rights. One of the
adequate remedy in the ordinary course of law, petitioners filed this basic rights is right against self-incrimination.

RSC HERMOGENES 2014