Bengzon vs Senate Blue Ribbon Committee
Political Law – Inquiry in Aid of Legislation – When not Allowed
It was alleged that Benjamin Kokoy Romualdez and his wife together with the Marcoses unlawfully and unjustly enriched themselves at the expense of the Filipino people. That they obtained with the help of the Bengzon law office and Ricardo Lopa – Cory’s brother in law, among others, control over some of the biggest business enterprises in the country including MERALCO, PCI Bank, Shell Philippines and Benguet Consolidated Mining Corporation. Sen. Enrile subsequently delivered a privilege speech alleging that Lopa took over various government owned corporations which is in violation of the Anti-Graft and Corrupt Practices Act. Contained in the speech is a motion to investigate on the matter. The motion was referred to the Committee on Accountability of Public Officers or the Blue Ribbon Committee. After committee hearing, Lopa refused to testify before the committee for it may unduly prejudice a pending civil case against him. Bengzon likewise refused invoking his right to due process. Lopa however sent a letter to Enrile categorically denying his allegations and that his allegations are baseless and malicious. Enrile subsequently took advantage of the Senate’s privilege hour upon which he insisted to have an inquiry regarding the matter. The SBRC rejected Lopa’s and Bengzon’s plea. Claiming that the Senate Blue Ribbon Committee is poised to subpoena them and require their attendance and testimony in proceedings before the Committee, in excess of its jurisdiction and legislative purpose, in clear and blatant disregard of their constitutional rights, and to their grave and irreparable damage, prejudice and injury, and that there is no appeal nor any other plain, speedy and adequate remedy in the ordinary course of law, the Bengzon et al filed the present petition for prohibition with a prayer for temporary restraining order and/or injunctive relief.
ISSUE: Whether or not the inquiry sought by the SBRC be granted.
HELD: No, the inquiry cannot be given due course. The speech of Enrile contained no suggestion of contemplated legislation; he merely called upon the Senate to look into a possible violation of Sec. 5 of RA No. 3019, otherwise known as “The Anti-Graft and Corrupt Practices Act.” In other words, the purpose of the inquiry to be conducted by the Blue Ribbon Committee was to find out whether or not the relatives of Cory, particularly Lopa, had violated the law in connection with the alleged sale of the 36 or 39 corporations belonging to Kokoy to the Lopa Group. There appears to be, therefore, no intended legislation involved. Hence, the contemplated inquiry by the SBRC 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.