Bengzon v Blue Ribbon Committee

Facts: 1. 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.
2. 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." 3. At the hearing, Lopa declined to testify on the
ground that his testimony may "unduly prejudice" the defendants in civil case before the
Sandiganbayan. 4. 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: W/N the Blue Ribbon inquiry was in aid of legislation

NO. 1. 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.

2.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.

3. 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.

4. 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.