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    Bengzon v. Senate Blue Ribbon (G.R. No. 89914)

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    Roward
    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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    Bengzon v. Senate Blue Ribbon (G.R. No. 89914)

    Uploaded by

    Roward
    3K views2 pages
    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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    Bengzon v. Senate Blue Ribbon [G.R. No. 89914]

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    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.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    3K views2 pages

    Bengzon v. Senate Blue Ribbon (G.R. No. 89914)

    Uploaded by

    Roward
    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.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    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.

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