G.R. No. 180308 ; June 19, 2012
PHILCOMSAT HOLDINGS CORPORATION, ENRIQUE L. LOCSIN AND MANUEL D. ANDAL, Petitioners, vs. SENATE OF THE REPUBLIC OF THE PHILIPPINES, SENATE COMMITTEE ON GOVERNMENT CORPORATIONS AND PUBLIC ENTERPRISES, SENATE COMMITTEE ON PUBLIC SERVICES, HON. SEN. RICHARD GORDON AND HON. SEN. JUAN PONCE ENRILE, Respondents.

FACTS

The Philippine Communications Satellite Corporation (PHILCOMSAT) is a subsidiary of the government-sequestered Philippine Overseas Telecommunications Corporation (POTC). Petitioner PHILCOMSAT Holdings Corporation (PHC) is a private holding company for PHILCOMSAT, while petitioners Enrique L. Locsin and Manuel D. Andal are directors of PHC and government nominees to the boards of POTC and PHILCOMSAT. Due to reported anomalous losses and mismanagement in these corporations from 1998 to 2005, Senator Miriam Defensor Santiago introduced Proposed Senate Resolution No. 455, directing an inquiry in aid of legislation. The Senate Committees on Government Corporations and Public Enterprises and on Public Services conducted public hearings, inviting Locsin and Andal as resource persons.
The Committees subsequently submitted Committee Report No. 312, which found overwhelming mismanagement by the Presidential Commission on Good Government (PCGG) and its nominees. The Report recommended, among others, the privatization of government shares and the replacement of government nominees. Petitioners filed this Petition for Certiorari and Prohibition, assailing the Report’s approval by the Senate as hasty and alleging grave abuse of discretion. They specifically claimed Senator Gordon acted with bias and denied them their right to counsel, and that Senator Enrile improperly participated despite recusing himself.

ISSUE

Whether the respondent Senate committed grave abuse of discretion amounting to lack or excess of jurisdiction in approving Committee Report No. 312.

RULING

The Supreme Court dismissed the petition. The Court ruled that the Senate Committees’ power of inquiry, anchored on Article VI, Section 21 of the Constitution , had already been upheld in the consolidated Sabio cases. This constitutional provision grants Congress and its committees the authority to conduct inquiries in aid of legislation in accordance with duly published rules, and such conferral carries all powers necessary for its effective discharge. Consequently, the Committees cannot be said to have acted with grave abuse of discretion in submitting the Report, nor can the Senate be faulted for approving it on the same day it was submitted. The wide latitude accorded to Congress in legislative inquiries is settled, lest the constitutional mandate be rendered pointless.
The petitioners’ ancillary claims were also without merit. The alleged denial of the right to counsel is specious, as this right attaches only during custodial investigation of a person suspected of a crime, not during legislative hearings where petitioners participated as resource persons. Furthermore, the core issues raised had become academic in light of the final ruling in the Sabio cases, which the parties themselves acknowledged in their pleadings. Thus, no grave abuse of discretion was found.