in Re Petition For Issuance of Writ of Habeas Corpus of Camilo L. Sabio
in Re Petition For Issuance of Writ of Habeas Corpus of Camilo L. Sabio
687
EN BANC
[ G.R. NO. 174340, October 17, 2006 ]
IN THE MATTER OF THE PETITION FOR ISSUANCE OF WRIT
OF HABEAS CORPUS OF CAMILO L. SABIO, PETITIONER, J.
ERMIN ERNEST LOUIE R. MIGUEL, PETITIONER-RELATOR,
VS. HONORABLE SENATOR RICHARD GORDON, IN HIS
CAPACITY AS CHAIRMAN, AND THE HONORABLE
MEMBERS OF THE COMMITTEE ON GOVERNMENT
CORPORATIONS AND PUBLIC ENTERPRISES AND THE
COMMITTEE ON PUBLIC SERVICES OF THE SENATE,
HONORABLE SENATOR JUAN PONCE-ENRILE, IN HIS
OFFICIAL CAPACITY AS MEMBER, HONORABLE MANUEL
VILLAR, SENATE PRESIDENT, SENATE SERGEANT-AT-ARMS,
AND THE SENATE OF THE PHILIPPINES, RESPONDENTS.
DECISION
SANDOVAL-GUTIERREZ, J.:
Two decades ago, on February 28, 1986, former President Corazon C. Aquino
installed her regime by issuing Executive Order (E.O.) No. 1,[1] creating the
Presidential Commission on Good Government (PCGG). She entrusted upon this
Commission the herculean task of recovering the ill-gotten wealth accumulated by the
deposed President Ferdinand E. Marcos, his family, relatives, subordinates and close
associates.[2] Section 4 (b) of E.O. No. 1 provides that: "No member or staff of the
Commission shall be required to testify or produce evidence in any judicial,
legislative or administrative proceeding concerning matters within its official
cognizance." Apparently, the purpose is to ensure PCGG's unhampered performance
of its task.[3]
Today, the constitutionality of Section 4(b) is being questioned on the ground that it
tramples upon the Senate's power to conduct legislative inquiry under Article VI,
Section 21 of the 1987 Constitution, which reads:
Adopted.
On the same date, February 20, 2006, Senate Res. No. 455 was submitted to the
Senate and referred to the Committee on Accountability of Public Officers and
Investigations and Committee on Public Services. However, on March 28, 2006, upon
motion of Senator Francis N. Pangilinan, it was transferred to the Committee on
Government Corporations and Public Enterprises.[5]
On May 8, 2006, Chief of Staff Rio C. Inocencio, under the authority of Senator
Richard J. Gordon, wrote Chairman Camilo L. Sabio of the PCGG, one of the herein
petitioners, inviting him to be one of the resource persons in the public meeting jointly
conducted by the Committee on Government Corporations and Public Enterprises and
Committee on Public Services. The purpose of the public meeting was to deliberate
on Senate Res. No. 455.[6]
Again, Chairman Sabio refused to appear. In his letter to Senator Gordon dated
August 18, 2006, he reiterated his earlier position, invoking Section 4(b) of E.O. No.
1. On the other hand, the directors and officers of Philcomsat Holdings Corporation
relied on the position paper they previously filed, which raised issues on the propriety
of legislative inquiry.
Thereafter, Chief of Staff Ma. Carissa O. Coscolluela, under the authority of Senator
Gordon, sent another notice[10] to Chairman Sabio requiring him to appear and testify
on the same subject matter set on September 6, 2006. The notice was issued "under
the same authority of the Subpoena Ad Testificandum previously served upon (him)
last 16 August 2006."
Once more, Chairman Sabio did not comply with the notice. He sent a letter[11] dated
September 4, 2006 to Senator Gordon reiterating his reason for declining to appear in
the public hearing.
This prompted Senator Gordon to issue an Order dated September 7, 2006 requiring
Chairman Sabio and Commissioners Abcede, Conti, Javier and Nario to show cause
why they should not be cited in contempt of the Senate. On September 11, 2006, they
submitted to the Senate their Compliance and Explanation,[12] which partly reads:
With all due respect, Section 4(b) of E.O. No. 1 constitutes a limitation on
the power of legislative inquiry, and a recognition by the State of the need
to provide protection to the PCGG in order to ensure the unhampered
performance of its duties under its charter. E.O. No. 1 is a law, Section
4(b) of which had not been amended, repealed or revised in any way.
To say the least, it would require both Houses of Congress and Presidential
fiat to amend or repeal the provision in controversy. Until then, it stands to
be respected as part of the legal system in this jurisdiction. (As held in
People v. Veneracion, G.R. Nos. 119987-88, October 12, 1995: Obedience
to the rule of law forms the bedrock of our system of justice. If judges,
under the guise of religious or political beliefs were allowed to roam
unrestricted beyond boundaries within which they are required by law to
exercise the duties of their office, then law becomes meaningless. A
government of laws, not of men excludes the exercise of broad
discretionary powers by those acting under its authority. Under this
system, judges are guided by the Rule of Law, and ought to 'protect and
enforce it without fear or favor,' 4 [Act of Athens (1955)] resist
encroachments by governments, political parties, or even the interference
of their own personal beliefs.)
Relevantly, Chairman Sabio's letter to Sen. Gordon dated August 19, 2006
pointed out that the anomalous transactions referred to in the P.S.
Resolution No. 455 are subject of pending cases before the regular courts,
the Sandiganbayan and the Supreme Court (Pending cases include: a.
Samuel Divina v. Manuel Nieto, Jr., et al., CA-G.R. No. 89102; b.
Philippine Communications Satellite Corporation v. Manuel Nieto, et al.;
c. Philippine Communications Satellite Corporation v. Manuel D. Andal,
Civil Case No. 06-095, RTC, Branch 61, Makati City; d. Philippine
Communications Satellite Corporation v. PHILCOMSAT Holdings
Corporation, et al., Civil Case No. 04-1049) for which reason they may
not be able to testify thereon under the principle of sub judice. The
laudable objectives of the PCGG's functions, recognized in several cases
decided by the Supreme Court, of the PCGG will be put to naught if its
recovery efforts will be unduly impeded by a legislative investigation of
cases that are already pending before the Sandiganbayan and trial courts.
On September 12, 2006, at around 10:45 a.m., Major General Balajadia arrested
Chairman Sabio in his office at IRC Building, No. 82 EDSA, Mandaluyong City and
brought him to the Senate premises where he was detained.
Hence, Chairman Sabio filed with this Court a petition for habeas corpus against the
Senate Committee on Government Corporations and Public Enterprises and
Committee on Public Services, their Chairmen, Senators Richard Gordon and Joker P.
Arroyo and Members. The case was docketed as G.R. No. 174340.
Chairman Sabio, Commissioners Abcede, Conti, Nario, and Javier, and the
PCGG�s nominees to Philcomsat Holdings Corporation, Manuel Andal and Julio
Jalandoni, likewise filed a petition for certiorari and prohibition against the same
respondents, and also against Senate President Manuel Villar, Senator Juan Ponce
Enrile, the Sergeant-at-Arms, and the entire Senate. The case was docketed as G.R.
No. 174318.
Meanwhile, Philcomsat Holdings Corporation and its officers and directors, namely:
Philip G. Brodett, Luis K. Lokin, Jr., Roberto V. San Jose, Delfin P. Angcao, Roberto
L. Abad, Alma Kristina Alobba and Johnny Tan filed a petition for certiorari and
prohibition against the Senate Committees on Government Corporations and Public
Enterprises and Public Services, their Chairmen, Senators Gordon and Arroyo, and
Members. The case was docketed as G.R. No. 174177.
In G.R. No. 174340 (for habeas corpus) and G.R. No. 174318 (for certiorari and
prohibition) Chairman Sabio, Commissioners Abcede, Conti, Nario, and Javier; and
the PCGG's nominees Andal and Jalandoni alleged: first, respondent Senate
Committees disregarded Section 4(b) of E.O. No. 1 without any justifiable reason;
second, the inquiries conducted by respondent Senate Committees are not in aid of
legislation; third, the inquiries were conducted in the absence of duly published Senate
Rules of Procedure Governing Inquiries in Aid of Legislation; and fourth, respondent
Senate Committees are not vested with the power of contempt.
In G.R. No. 174177, petitioners Philcomsat Holdings Corporation and its directors and
officers alleged: first, respondent Senate Committees have no jurisdiction over the
subject matter stated in Senate Res. No. 455; second, the same inquiry is not in
accordance with the Senate's Rules of Procedure Governing Inquiries in Aid of
Legislation; third, the subpoenae against the individual petitioners are void for having
been issued without authority; fourth, the conduct of legislative inquiry pursuant to
Senate Res. No. 455 constitutes undue encroachment by respondents into justiciable
controversies over which several courts and tribunals have already acquired
jurisdiction; and fifth, the subpoenae violated petitioners' rights to privacy and against
self-incrimination.
Crucial to the resolution of the present petitions is the fundamental issue of whether
Section 4(b) of E.O. No. 1 is repealed by the 1987 Constitution. On this lone issue
hinges the merit of the contention of Chairman Sabio and his Commissioners that their
refusal to appear before respondent Senate Committees is justified. With the
resolution of this issue, all the other issues raised by the parties have become
inconsequential.
Perched on one arm of the scale of justice is Article VI, Section 21 of the 1987
Constitution granting respondent Senate Committees the power of legislative inquiry.
It reads:
On the other arm of the scale is Section 4(b) of E.O. No.1 limiting such power of
legislative inquiry by exempting all PCGG members or staff from testifying in any
judicial, legislative or administrative proceeding, thus:
To determine whether there exists a clear and unequivocal repugnancy between the
two quoted provisions that warrants a declaration that Section 4(b) has been repealed
by the 1987 Constitution, a brief consideration of the Congress' power of inquiry is
imperative.
The Congress' power of inquiry has been recognized in foreign jurisdictions long
before it reached our shores through McGrain v. Daugherty,[15] cited in Arnault v.
Nazareno.[16] In those earlier days, American courts considered the power of inquiry
as inherent in the power to legislate. The 1864 case of Briggs v. MacKellar[17]
explains the breath and basis of the power, thus:
Where no constitutional limitation or restriction exists, it is competent for
either of the two bodies composing the legislature to do, in their separate
capacity, whatever may be essential to enable them to legislate....It is
well-established principle of this parliamentary law, that either house may
institute any investigation having reference to its own organization, the
conduct or qualification of its members, its proceedings, rights, or
privileges or any matter affecting the public interest upon which it may
be important that it should have exact information, and in respect to
which it would be competent for it to legislate. The right to pass laws,
necessarily implies the right to obtain information upon any matter
which may become the subject of a law. It is essential to the full and
intelligent exercise of the legislative function....In American
legislatures the investigation of public matters before committees,
preliminary to legislation, or with the view of advising the house
appointing the committee is, as a parliamentary usage, well established
as it is in England, and the right of either house to compel witnesses to
appear and testify before its committee, and to punish for disobedience has
been frequently enforced....The right of inquiry, I think, extends to other
matters, in respect to which it may be necessary, or may be deemed
advisable to apply for legislative aid.
Notably, the 1987 Constitution recognizes the power of investigation, not just of
Congress, but also of "any of its committee." This is significant because it constitutes
a direct conferral of investigatory power upon the committees and it means that the
mechanisms which the Houses can take in order to effectively perform its
investigative function are also available to the committees.[20]
It can be said that the Congress' power of inquiry has gained more solid existence and
expansive construal. The Court's high regard to such power is rendered more
evident in Senate v. Ermita,[21] where it categorically ruled that "the power of
inquiry is broad enough to cover officials of the executive branch." Verily, the
Court reinforced the doctrine in Arnault that "the operation of government, being a
legitimate subject for legislation, is a proper subject for investigation" and that
"the power of inquiry is co-extensive with the power to legislate."
Certainly, a mere provision of law cannot pose a limitation to the broad power of
Congress, in the absence of any constitutional basis.
Furthermore, Section 4(b) is also inconsistent with Article XI, Section 1 of the
Constitution stating that: "Public office is a public trust. Public officers and employees
must at all times be accountable to the people, serve them with utmost responsibility,
integrity, loyalty, and efficiency, act with patriotism and justice, and lead modest
lives."
The provision presupposes that since an incumbent of a public office is invested with
certain powers and charged with certain duties pertinent to sovereignty, the powers so
delegated to the officer are held in trust for the people and are to be exercised in
behalf of the government or of all citizens who may need the intervention of the
officers. Such trust extends to all matters within the range of duties pertaining to
the office. In other words, public officers are but the servants of the people, and
not their rulers.[24]
Section 4(b), being in the nature of an immunity, is inconsistent with the principle of
public accountability. It places the PCGG members and staff beyond the reach of
courts, Congress and other administrative bodies. Instead of encouraging public
accountability, the same provision only institutionalizes irresponsibility and non-
accountability. In Presidential Commission on Good Government v. Peña,[25] Justice
Florentino P. Feliciano characterized as "obiter" the portion of the majority opinion
barring, on the basis of Sections 4(a) and (b) of E.O. No. 1, a civil case for damages
filed against the PCGG and its Commissioners. He eloquently opined:
Chavez v. Sandiganbayan[26] reiterates the same view. Indeed, Section 4(b) has been
frowned upon by this Court even before the filing of the present petitions.
Corollarily, Section 4(b) also runs counter to the following constitutional provisions
ensuring the people's access to information:
Section 4(b) limits or obstructs the power of Congress to secure from PCGG members
and staff information and other data in aid of its power to legislate. Again, this must
not be countenanced. In Senate v. Ermita,[31] this Court stressed:
The clear import of this provision is that all existing laws, executive orders,
proclamations, letters of instructions and other executive issuances inconsistent or
repugnant to the Constitution are repealed.
These Decisions, and many others, highlight that the Constitution is the highest law of
the land. It is "the basic and paramount law to which all other laws must conform
and to which all persons, including the highest officials of the land, must defer.
No act shall be valid, however noble its intentions, if it conflicts with the
Constitution."[37] Consequently, this Court has no recourse but to declare Section
4(b) of E.O. No. 1 repealed by the 1987 Constitution.
Significantly, during the oral arguments on September 21, 2006, Chairman Sabio
admitted that should this Court rule that Section 4(b) is unconstitutional or that it does
not apply to the Senate, he will answer the questions of the Senators, thus:
CHAIRMAN SABIO:
Your Honor, my father was a judge, died being a judge. I was here in
the Supreme Court as Chief of Staff of Justice Feria. I would
definitely honor the Supreme Court and the rule of law.
CHAIRMAN SABIO:
With his admission, Chairman Sabio is not fully convinced that he and his
Commissioners are shielded from testifying before respondent Senate Committees by
Section 4(b) of E.O. No. 1. In effect, his argument that the said provision exempts
him and his co-respondent Commissioners from testifying before respondent Senate
Committees concerning Senate Res. No. 455 utterly lacks merit.
It must be stressed that the Order of Arrest for "contempt of Senate Committees and
the Philippine Senate" was approved by Senate President Villar and signed by
fifteen (15) Senators. From this, it can be concluded that the Order is under the
authority, not only of the respondent Senate Committees, but of the entire Senate.
At any rate, Article VI, Section 21 grants the power of inquiry not only to the Senate
and the House of Representatives, but also to any of their respective committees.
Clearly, there is a direct conferral of power to the committees. Father Bernas, in his
Commentary on the 1987 Constitution, correctly pointed out its significance:
This is a reasonable conclusion. The conferral of the legislative power of inquiry upon
any committee of Congress must carry with it all powers necessary and proper for its
effective discharge. Otherwise, Article VI, Section 21 will be meaningless. The
indispensability and usefulness of the power of contempt in a legislative inquiry is
underscored in a catena of cases, foreign and local.
In the 1821 case of Anderson v. Dunn,[39] the function of the Houses of Congress
with respect to the contempt power was likened to that of a court, thus:
...But the court in its reasoning goes beyond this, and though the grounds
of the decision are not very clearly stated, we take them to be: that there is
in some cases a power in each House of Congress to punish for
contempt; that this power is analogous to that exercised by courts of
justice, and that it being the well established doctrine that when it
appears that a prisoner is held under the order of a court of general
jurisdiction for a contempt of its authority, no other court will
discharge the prisoner or make further inquiry into the cause of his
commitment. That this is the general rule...as regards the relation of one
court to another must be conceded.
In McGrain,[40] the U.S. Supreme Court held: "Experience has shown that mere
requests for such information are often unavailing, and also that information
which is volunteered is not always accurate or complete; so some means of
compulsion is essential to obtain what is needed." The Court, in Arnault v.
Nazareno,[41] sustained the Congress' power of contempt on the basis of this
observation.
In Arnault v. Balagtas,[42] the Court further explained that the contempt power of
Congress is founded upon reason and policy and that the power of inquiry will not be
complete if for every contumacious act, Congress has to resort to judicial interference,
thus:
The principle that Congress or any of its bodies has the power to punish
recalcitrant witnesses is founded upon reason and policy. Said power must
be considered implied or incidental to the exercise of legislative power.
How could a legislative body obtain the knowledge and information on
which to base intended legislation if it cannot require and compel the
disclosure of such knowledge and information if it is impotent to
punish a defiance of its power and authority? When the framers of the
Constitution adopted the principle of separation of powers, making
each branch supreme within the realm of its respective authority, it
must have intended each department's authority to be full and
complete, independently of the other's authority or power. And how
could the authority and power become complete if for every act of
refusal, every act of defiance, every act of contumacy against it, the
legislative body must resort to the judicial department for the
appropriate remedy, because it is impotent by itself to punish or deal
therewith, with the affronts committed against its authority or dignity.
[43]
Meanwhile, with respect to G.R. No. 174177, the petition of Philcomsat Holdings
Corporation and its directors and officers, this Court holds that the respondent Senate
Committees' inquiry does not violate their right to privacy and right against self-
incrimination.
One important limitation on the Congress' power of inquiry is that "the rights of
persons appearing in or affected by such inquiries shall be respected." This is just
another way of saying that the power of inquiry must be "subject to the limitations
placed by the Constitution on government action." As held in Barenblatt v. United
States,[45] "the Congress, in common with all the other branches of the
Government, must exercise its powers subject to the limitations placed by the
Constitution on governmental action, more particularly in the context of this
case, the relevant limitations of the Bill of Rights."
Zones of privacy are recognized and protected in our laws.[46] Within these zones,
any form of intrusion is impermissible unless excused by law and in accordance with
customary legal process. The meticulous regard we accord to these zones arises not
only from our conviction that the right to privacy is a "constitutional right" and "the
right most valued by civilized men,"[47] but also from our adherence to the Universal
Declaration of Human Rights which mandates that, "no one shall be subjected to
arbitrary interference with his privacy" and "everyone has the right to the protection
of the law against such interference or attacks."[48]
Our Bill of Rights, enshrined in Article III of the Constitution, provides at least two
guarantees that explicitly create zones of privacy. It highlights a person's "right to be
let alone" or the "right to determine what, how much, to whom and when information
about himself shall be disclosed."[49] Section 2 guarantees "the right of the
people to be secure in their persons, houses, papers and effects against
unreasonable searches and seizures of whatever nature and for any purpose."
Section 3 renders inviolable the "privacy of communication and
correspondence" and further cautions that "any evidence obtained in violation of
this or the preceding section shall be inadmissible for any purpose in any
proceeding."
In evaluating a claim for violation of the right to privacy, a court must determine
whether a person has exhibited a reasonable expectation of privacy and, if so, whether
that expectation has been violated by unreasonable government intrusion.[50]
Applying this determination to these cases, the important inquiries are: first, did the
directors and officers of Philcomsat Holdings Corporation exhibit a reasonable
expectation of privacy?; and second, did the government violate such expectation?
The answers are in the negative. Petitioners were invited in the Senate's public hearing
to deliberate on Senate Res. No. 455, particularly "on the anomalous losses incurred
by the Philippine Overseas Telecommunications Corporation (POTC), Philippine
Communications Satellite Corporation (PHILCOMSAT), and Philcomsat
Holdings Corporations (PHC) due to the alleged improprieties in the operations
by their respective board of directors." Obviously, the inquiry focus on petitioners'
acts committed in the discharge of their duties as officers and directors of the said
corporations, particularly Philcomsat Holdings Corporation. Consequently, they
have no reasonable expectation of privacy over matters involving their offices in
a corporation where the government has interest. Certainly, such matters are of
public concern and over which the people have the right to information.
This goes to show that the right to privacy is not absolute where there is an overriding
compelling state interest. In Morfe v. Mutuc,[51] the Court, in line with Whalen v.
Roe,[52] employed the rational basis relationship test when it held that there was no
infringement of the individual's right to privacy as the requirement to disclosure
information is for a valid purpose, i.e., to curtail and minimize the opportunities for
official corruption, maintain a standard of honesty in public service, and promote
morality in public administration.[53] In Valmonte v. Belmonte,[54] the Court remarked
that as public figures, the Members of the former Batasang Pambansa enjoy a more
limited right to privacy as compared to ordinary individuals, and their actions are
subject to closer scrutiny. Taking this into consideration, the Court ruled that the right
of the people to access information on matters of public concern prevails over the right
to privacy of financial transactions.
Under the present circumstances, the alleged anomalies in the PHILCOMSAT, PHC
and POTC, ranging in millions of pesos, and the conspiratorial participation of the
PCGG and its officials are compelling reasons for the Senate to exact vital
information from the directors and officers of Philcomsat Holdings Corporations, as
well as from Chairman Sabio and his Commissioners to aid it in crafting the necessary
legislation to prevent corruption and formulate remedial measures and policy
determination regarding PCGG's efficacy. There being no reasonable expectation of
privacy on the part of those directors and officers over the subject covered by Senate
Res. No. 455, it follows that their right to privacy has not been violated by respondent
Senate Committees.
Anent the right against self-incrimination, it must be emphasized that this right maybe
invoked by the said directors and officers of Philcomsat Holdings Corporation only
when the incriminating question is being asked, since they have no way of
knowing in advance the nature or effect of the questions to be asked of them."[55]
That this right may possibly be violated or abused is no ground for denying
respondent Senate Committees their power of inquiry. The consolation is that when
this power is abused, such issue may be presented before the courts. At this juncture,
what is important is that respondent Senate Committees have sufficient Rules to guide
them when the right against self-incrimination is invoked. Sec. 19 reads:
Sec. 19. Privilege Against Self-Incrimination
The same directors and officers contend that the Senate is barred from inquiring into
the same issues being litigated before the Court of Appeals and the Sandiganbayan.
Suffice it to state that the Senate Rules of Procedure Governing Inquiries in Aid of
Legislation provide that the filing or pendency of any prosecution of criminal or
administrative action should not stop or abate any inquiry to carry out a legislative
purpose.
Let it be stressed at this point that so long as the constitutional rights of witnesses,
like Chairman Sabio and his Commissioners, will be respected by respondent Senate
Committees, it their duty to cooperate with them in their efforts to obtain the facts
needed for intelligent legislative action. The unremitting obligation of every citizen is
to respond to subpoenae, to respect the dignity of the Congress and its Committees,
and to testify fully with respect to matters within the realm of proper investigation.
In fine, PCGG Chairman Camilo Sabio and Commissioners Ricardo Abcede, Narciso
Nario, Nicasio Conti, and Tereso Javier; and Manuel Andal and Julio Jalandoni,
PCGG's nominees to Philcomsat Holdings Corporation, as well as its directors and
officers, must comply with the Subpoenae Ad Testificandum issued by respondent
Senate Committees directing them to appear and testify in public hearings relative to
Senate Resolution No. 455.
WHEREFORE, the petition in G.R. No. 174340 for habeas corpus is DISMISSED,
for being moot. The petitions in G.R Nos. 174318 and 174177 are likewise
DISMISSED.
SO ORDERED.
[1] E.O. No. 1 was issued by Former President Aquino in the exercise of her legislative
power under the Provisional (Freedom) Constitution. Thus, it is of the same category
and has the same binding force as a statute. (Agpalo, Statutory Construction, 1998
citing Legaspi v. Ministry of Finance, 115 SCRA 418 [1982]; Garcia-Padilla v. Ponce
Enrile, G.R. No. 61388, April 20, 1983; Aquino v. Commission on Elections, 62
SCRA 275 [1975] )
[3]
See Presidential Commission on Good Government v. Pena, April 12, 1988, 159
SCRA 558
[5] Id.
[15] 273 U.S. 135, 47 S. Ct. 319, 71 L. Ed. 580, 50 A.L.R. 1 (1927).
[18] Puno, Lecture on Legislative Investigations and the Right to Privacy, at p. 22.
[19]Bernas S.J., The 1987 Constitution of the Republic of the Philippines, 2003 Ed. at
p.737.
[20]Bernas S.J., The 1987 Constitution of the Republic of the Philippines, 2003 Ed. at
p.739.
[22] Watkins v. United States, 354 U.S. 178 (1957), pp. 194-195.
[24] De Leon, De Leon, Jr. The Law on Public Officers and Election Law, p. 2.
[27] G.R. No. 74930, February 13, 1989, 170 SCRA 256.
[28] Valmonte v. Belmonte, Jr., supra.
[31] Supra.
[32] Agpalo, Statutory Construction, 1998 citing In re Cunanan, 94 Phil. 534 (1954).
[35] G.R. No. 152774, May 27, 2004, 429 SCRA 736.
[38]
A Bernas, S.J., The 1987 Constitution of the Republic of the Philippines A
Commentary, p. 678.
[39]19 U.S. [6 Wheat.] 204 (1821) cited in Justice Puno, Legislative Investigations
and Right to Privacy.
[40] Supra.
[41] Supra.
[47] See Morfe v. Mutuc No. L-20387, January 31, 1968, 22 SCRA 424.
[48]Article 12 of the Universal Declaration of Human Rights. See also Article 17 (1)
and (2) of the International Covenant on Civil and Political Rights.
[51] Supra.
[53] Justice Puno, Lecture on Legislative Inquiry and Right to Privacy, p. 60.
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