GR 257608; (July, 2022) (Digest)
G.R. No. 257608 , July 5, 2022
THE SENATE OF THE PHILIPPINES, ET AL., PETITIONERS, VS. THE EXECUTIVE SECRETARY SALVADOR C. MEDIALDEA AND SECRETARY OF HEALTH FRANCISCO T. DUQUE III, RESPONDENTS.
FACTS
The Senate Blue Ribbon Committee initiated an inquiry in aid of legislation concerning the Department of Health’s (DOH) utilization of its ₱77 billion COVID-19 response budget, following a Commission on Audit report noting a ₱67 billion deficiency. The investigation focused on procurement processes, fund disbursements, and potential irregularities in purchases like personal protective equipment. During the hearings, President Rodrigo Duterte complained about the alleged “browbeating” of executive officials.
This culminated in the issuance of a Memorandum dated October 4, 2021, by the Executive Secretary, upon the President’s directive. The Memorandum prohibited all officials and employees of the Executive Department from attending the Senate hearings. It asserted that the inquiry was no longer in aid of legislation but was aimed at identifying persons to hold accountable, thereby allegedly encroaching on the mandates of other branches and hindering the Executive’s ability to fulfill its core functions during the pandemic.
ISSUE
Whether the President, through the Executive Secretary, committed grave abuse of discretion in issuing the Memorandum that barred executive officials from attending the Senate Blue Ribbon Committee’s inquiry.
RULING
Yes, the Supreme Court En Banc ruled that the issuance of the Memorandum constituted grave abuse of discretion. The Court emphasized the constitutional principle of separation of powers, which is not absolute but is tempered by a system of checks and balances. The Senate’s power of inquiry, expressly granted under Section 21, Article VI of the Constitution , is a vital component of this system, enabling it to gather information necessary for legislation.
The Court found that the Senate Committee’s inquiry was legitimate and in aid of legislation. The subject matter—the expenditure of massive public funds for the pandemic response—was plainly within the scope of potential legislative action, as evidenced by several pending Senate bills addressing COVID-19 benefits and health fund management. The President’s blanket prohibition, based on a unilateral conclusion that the inquiry was not legislative in purpose, was an overreach. It preemptively judged the Senate’s intent and obstructed a co-equal branch from performing its constitutional duty without sufficient justification. The Memorandum effectively arrogated unto the Executive the sole authority to determine the legitimacy of a congressional inquiry, thereby violating the doctrine of separation of powers. Consequently, the Court granted the petition and declared the Memorandum void.