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Sabio v. Gordon: Constitutional Inquiry Limits

This case involved a dispute between Senator Richard Gordon and Camilo Sabio, the Chairman of the Philippine Commission on Good Government (PCGG). Gordon had invited Sabio to participate in a public Senate meeting regarding losses incurred by government corporations. However, Sabio declined the invitation, citing a provision that exempted PCGG members from testifying in legislative proceedings regarding matters under its purview. Gordon then issued subpoenas against Sabio and threatened him with contempt. The Supreme Court ultimately ruled that the exemption provision was unconstitutional, as it violated Congress' broad power of inquiry and the people's right to access information under the Constitution.

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83 views1 page

Sabio v. Gordon: Constitutional Inquiry Limits

This case involved a dispute between Senator Richard Gordon and Camilo Sabio, the Chairman of the Philippine Commission on Good Government (PCGG). Gordon had invited Sabio to participate in a public Senate meeting regarding losses incurred by government corporations. However, Sabio declined the invitation, citing a provision that exempted PCGG members from testifying in legislative proceedings regarding matters under its purview. Gordon then issued subpoenas against Sabio and threatened him with contempt. The Supreme Court ultimately ruled that the exemption provision was unconstitutional, as it violated Congress' broad power of inquiry and the people's right to access information under the Constitution.

Uploaded by

Steve Ambalong
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We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd

SABIO v.

GORDON

504 SCRA 704, 17 OCTOBER 2006

FACTS:

➢ In February 2006, Senator Miriam Defensor-Santiago introduced Senate Res. No. 455, directing
an inquiry in aid of legislation on the anomalous losses incurred by the POTC, PHILCOMSAT, and
PHC. The losses were allegedly due to improprieties in their operations by their respective Board
of Directors.
➢ On May 8, 2006, Senator Richard Gordon invited Chairman Camilo Sabio of the PCGG to
participate in a public meeting. The public meeting was jointly conducted by the Committee on
Government Corporations and Public Enterprises and Committee on Public Services.
➢ Chairman Sabio declined the invitation due to a prior commitment.
➢ Chairman Sabio invoked Section 4(b) of E.O. No. 1, which exempts Commission members from
testifying or producing evidence in any judicial, legislative, or administrative proceeding
concerning matters within its official cognizance. The purpose of the invocation was to ensure
the PCGG's unhampered performance of its tasks.
➢ Several subpoenas were then issued to Chairman Sabio and he was subsequently threatened to
be cited in contempt.

ISSUE:

➢ W.O.N Section 4 of EO No. 1 is constitutional under .

HELD:

➢ NO. 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, 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 legislate1."
➢ Corollarily, Section 4(b) also runs counter to the following constitutional provisions ensuring the
people's access to information:

Article II, Section 28

Subject to reasonable conditions prescribed by law, the State adopts and implements a policy
of full public disclosure of all its transactions involving public interest.

Article III, Section 7

The right of the people to information on matters of public concern shall be recognized. Access
to official records, and to documents, and papers pertaining to official acts, transactions, or
decisions, as well as to government research data used as basis for policy development, shall be
afforded the citizen, subject to such limitations as may be provided by law2.
➢ An essential element of these freedoms is to keep open a continuing dialogue or process of
communication between the government and the people. It is in the interest of the State that the
channels for free political discussion be maintained to the end that the government may
perceive and be responsive to the people's will. Yet, this open dialogue can be effective only to
the extent that the citizenry is informed and thus able to formulate its will intelligently. Only when
the participants in the discussion are aware of the issues and have access to information relating
thereto can such bear fruit3.

1
G.R. No. 174340 - The Lawphil Project. [Link]
2
Ibid.
3
Ibid.

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