Senate Blue Ribbon Committee vs. Majaducon (G.R. No. 136760)

Facts:

This case had its aegis when the Senate Blue Ribbon Committee conducted an inquiry into the alleged mismanagement of the funds and investment of the Armed Forces Retirement and Separation Benefits System (AFP-RSBS). During the public hearings by the Blue Ribbon Committee, it appeared that the AFP-RSBS purchased a lot from Atty. Nilo J. Flaviano worth P10,500 per square meter. However, the deed of sale filed with the Register of Deeds indicated that the purchase price of the lot was only P3,000 per square meter. The Committee caused the service of a subpoena to Atty. Flaviano, directing him to appear and testify before it. Respondent refused to appear and filed a petition for prohibition and preliminary injunction with prayer for temporary restraining order with the RTC of General Santos City. The trial court issued a TRO directing the committee to cease and desist from proceeding with the inquiry. The Committee filed a motion to dismiss on the ground of lack of jurisdiction and failure to state a valid cause of action. The Trial Court denied the motion to dismiss. Hence, this petition for certiorari alleging that Judge Majaducon committed grave abuse of discretion and acted without or in excess of jurisdiction.

Issue:

Whether or not respondent Judge Jose Majaducon committed grave abuse of discretion when he dismissed the petition for prohibition and issued the writ of preliminary injunction.

Ruling:

The assailed resolution of respondent Judge Majaducon was issued without legal basis. The principle of separation of powers essentially means that legislation belongs to Congress, execution to the Executive, and settlement of legal controversies to the Judiciary. Each is prevented from invading the domain of the others. When the Senate Blue Ribbon Committee served subpoena on respondent Flaviano to appear and testify before it in connection with its investigation of the alleged misuse and mismanagement of the AFP-RSBS funds, it did so pursuant to its authority to conduct inquiries in aid of legislation. This is clearly provided in Article 6, Section 21 of the 1987 Constitution:

The Senate of the House of Representatives or any of its respective committees may conduct inquiries in aid of legislation in accordance with its duly published rules of procedure. The rights of persons appearing in or affected by such inquiries shall be respected.

Hence, the RTC of General Santos City, or any court for that matter, had no authority to prohibit the Committee from requiring respondent t appear and testify before it. 

Also, the ruling in Bengzon vs. Blue Ribbon Committee cited by the respondent does not apply in this case. The factual circumstances therein are different from those in the case at bar. In Bengzon, no intended legislation was involved and the subject matter of the inquiry was more within the province of the courts rather than the legislature. On the other hand, there was in this case a clear legislative purpose, and this is to look into the reported misuse and mismanagement of the AFP-RSBS funds, with the intention of enacting appropriate legislation to protect the rights and interests of the officers and members of the Armed Forces of the Philippines.

Wherefore, the petition is GRANTED.