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G.R. No. 184849 – 579 SCRA 521 – Political Law – Constitutional Law – Legislative Branch – Powers of Congress – Inquiry in Aid of Legislation – A Senate Committee may issue arrest warrants to compel witness – Senate Rules cannot be inquired into by the Courts
In October 2008, Gen. Eliseo Dela Paz, a senior officer of the PNP, headed a delegation of eight to attend an Interpol General Assembly. Dela Paz brought with him his wife. Three days after the scheduled Interpol assembly, Dela Paz was also to retire. After the assembly, Dela Paz was apprehended in the departure area for he was carrying with him €105,000.00 (P6,930,000.00). He was also carrying with him €45,000.00 (P2,970,000.00). He failed to declare in writing that he is carrying such an amount and this is in violation of the United Nations Convention Against Corruption and the United Nations Convention Against Transnational Organized Crime. Dela Paz and his group was later released but the Euros were confiscated by the Russians. Upon arrival in the Philippines, Dela Paz was issued a subpoena by the Senate Committee on Foreign Relations for the investigation it was to conduct involving the Moscow incident. Instead of appearing before the senate committee, Dela Paz averred that the said committee does not have jurisdiction of the case. Dela Paz argued that the Committee is devoid of any jurisdiction to investigate the Moscow incident as the matter does not involve state to state relations as provided in paragraph 12, Section 13, Rule 10 of the Senate Rules of Procedure (Senate Rules). Later, the committee issued a warrant of arrest against Dela Paz (his wife?). Dela Paz questioned the warrant as he claimed that the Senate Rules required the signatures of the majority of the members of the Committee which was not obtained in this case.
ISSUE: Whether or not the said Committee has jurisdiction over the matter.
HELD: Yes. The SC ruled against Dela Paz. Section 16(3), Article VI of the Philippine Constitution states: “Each House shall determine the rules of its proceedings.” This provision has been traditionally construed as a grant of full discretionary authority to the Houses of Congress in the formulation, adoption and promulgation of its own rules. The challenge to the jurisdiction of the Senate Foreign Relations Committee, raised by petitioner in the case at bench, in effect, asks this Court to inquire into a matter that is within the full discretion of the Senate. The issue partakes of the nature of a political question. Also, the signatures were properly obtained as evidenced by the approval of the Senate president and it is shown that the gathering of the signatures is in accordance with the Rules. It is also shown that the Rules of Procedure Governing Inquiries in Aid of Legislation were also published in two newspapers of general circulation.
The warrant of arrest became ineffectual because Dela Paz voluntarily appeared prior to his arrest.