Bengzon, Jr. vs. The Senate Blue Ribbon Committee G.R. No. 89914, November 20, 1991

Facts: The Republic of the Philippines, represented by the PCGG, filed with the Sandiganbayan a civil case against Benjamin Romualdez. The complaint alleged that Benjamin Romualdez and Juliette Gomez Romualdez, acting by themselves and/or in unlawful concert with then President Ferdinand Marcos and Imelda Marcos, and taking undue advantage of their relationship, influence and connection with the latter spouses, engaged in devices, schemes and stratagems to unjustly enrich themselves at the expense of the Republic of the Philippines and the Filipino people.

Conflicting reports on the disposition by the PCGG of the Romualdez corporations were carried in various newspapers. Other newspapers declared that shortly after the 1986 EDSA Revolution, the Romualdez companies were sold for P5 million, without PCGG approval, to a holding company controlled by Romualdez, and that Ricardo Lopa, the President’s brother-in-law, had effectively taken over the firm.

In the Senate, Senator Enrile delivered a speech on the alleged take over by Lopa of SOLOIL Incorporated, the flagship of the First Manila Management of Companies owned by Romualdez. Senator Enrile also called upon the Senate to look into the possible violation of the law, particularly with regard to RA 3019, The Anti-Graft and Corrupt Practices Act. The matter was referred by the Senate to the Blue Ribbon Committee.


Issue: Whether or not the Senate Blue Ribbon Committee’s inquiry has valid legislative purpose as mandated by Art. VI, Sec. 21


Held: The Constitution expressly recognizes the power of both Houses of Congress to conduct inquiries in aid of legislation. But the power of both Houses of Congress to conduct inquiries in aid of legislation is not absolute or unlimited. As provided under Art. VI, Sec. 21, 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.

The power to conduct formal inquiries or investigations is specifically provided in the Senate Rules of Procedure. Such inquiries may refer to the implementation or re-examination of any law or in connection with any proposed legislation or the formulation of future legislation. They may also extend to any and all matters vested by the Constitution in Congress and/or in the Senate alone.

The speech of Senator Enrile contained no suggestion of contemplated legislation; he merely called upon the Senate to look into a possible violation of the Anti-Graft and Corrupt Practices Act. The purpose of the inquiry was to find out whether or not the relatives of President Aquino, particularly Lopa, had violated the law in connection with the alleged sale of 36 or 39 corporations belonging to Romualdez to the Lopa group. There appears to be, therefore, no intended legislation involved. This matter appears to be more within the province of the courts rather than of the legislature.