G.R. No. 89914 November 20, 1991
JOSE F.S. BENGZON JR., ET AL., petitioners, vs. THE SENATE BLUE RIBBON COMMITTEE AND ITS MEMBERS, ET AL., respondents.

FACTS

Petitioners, including lawyers and corporate managers, were impleaded as defendants in a pending Sandiganbayan case (Civil Case No. 0035) filed by the Presidential Commission on Good Government (PCGG). The suit alleged they conspired with Benjamin “Kokoy” Romualdez to illegally acquire and conceal assets, including through a purported sham sale of his corporate interests days after the PCGG’s creation. Concurrently, the respondent Senate Blue Ribbon Committee initiated an inquiry into this alleged sale. The Committee issued invitations and subsequently subpoenas to the petitioners, requiring their testimony and production of documents related to the transaction.
The petitioners filed this petition for prohibition, seeking to enjoin the Senate inquiry. They argued the investigation constituted a usurpation of judicial functions, as the very same facts and issues were the subject of the pending Sandiganbayan litigation. They contended the inquiry would violate their constitutional rights, including the right against self-incrimination, and would unduly prejudice their defense in the judicial case.

ISSUE

Whether the Senate Blue Ribbon Committee may proceed with its inquiry in aid of legislation into a matter that is simultaneously the subject of a pending judicial proceeding before the Sandiganbayan.

RULING

The Supreme Court DISMISSED the petition, upholding the power of the Senate Blue Ribbon Committee to proceed with its investigation. The Court clarified that the legislative inquiry and the judicial proceeding serve distinct constitutional purposes. The Sandiganbayan case is an in rem action for the recovery of ill-gotten wealth, a judicial function to settle specific controversies and enforce rights. In contrast, the Senate inquiry is an in personam exercise of the legislative power to obtain information for potential future legislation.
The Court held that the pendency of a judicial case does not automatically preclude a congressional investigation. The legislative power to inquire in aid of legislation is broad, inherent, and persists unless it is shown to be clearly devoid of any potential legislative purpose. The mere possibility that the inquiry might affect or overlap with a judicial case is not a sufficient ground for judicial prohibition. For the Court to interfere, there must be a clear showing of a grave abuse of discretion, such as if the investigation is being conducted solely to try a case already before the courts or to embarrass the parties therein. The respondents sufficiently articulated a legislative purpose—to determine the adequacy of existing laws on ill-gotten wealth and sequestered assets—which falls within the committee’s legitimate scope. The petitioners’ remedies for protecting specific rights, like against self-incrimination, lie in invoking them before the Committee itself, not in a blanket prohibition of the entire inquiry.