The Court’s Ruling

Upon judicious rumination, the Court resolves to dismiss the Petition and deny the prayer for the issuance of a TRO and/or writ of preliminary injunction.

Before delving into the merits of the case, this Court shall first pass upon the procedural issues.

Direct recourse to the Court is justified by
the transcendental nature and
exigency of the case

The Senate Committee postulates that the Petition should be dismissed since it involves the determination of factual issues sans any showing that direct resort to the Court was warranted under the exceptions, thereby disregarding the principle of hierarchy of courts.³¹

On the other hand, Guo asserts in her Petition that she raises novel questions of law, justifying her direct invocation of this Court’s jurisdiction.³² She further argues that the Petition sets forth questions of transcendental importance,³³ given that the Senate Committee violated her constitutional rights.

Well-ensconced is the rule that jurisdiction over petitions for certiorari and prohibition is shared by this Court, the Court of Appeals, the Sandiganbayan, and the regional trial courts.³⁴ Nevertheless, despite this shared original jurisdiction, parties do not have unfettered discretion in selecting the forum to which their application will be directed.³⁵ The litigant must first seek relief from lower courts sharing concurrent jurisdiction with a higher court.³⁶ The direct invocation of this Court’s original jurisdiction to issue these writs is allowed only when there are special and important reasons, which must be clearly and specifically set out in the petition.³⁷

Notwithstanding the foregoing, it has been decreed, time and again, that the Court retains full discretionary power to assume jurisdiction over petitions for certiorari filed directly with it when there are compelling reasons therefor.³⁸ In The Diocese of Bacolod v. COMELEC,³⁹ the Court enumerated such instances, to wit: (1) when there are genuine issues of constitutionality that must be addressed at the most immediate time; (2) when the issues involved are of transcendental importance; (3) in cases of first impression; (4) the constitutional issues raised are better decided by the Supreme Court; (5) the time element or exigency in certain situations; (6) the filed petition reviews an act of a constitutional organ; (7) when there is no other plain, speedy, and adequate remedy in the ordinary course of law; and (8) the petition includes questions that are dictated by public welfare and the advancement of public policy, or demanded by the broader interest of justice, or the orders complained of were found to be patent nullities, or the appeal was considered as clearly an inappropriate remedy.⁴⁰

As aptly pointed out by Guo, the second exception applies. Jurisprudence dictates that the imminence and clarity of the threat to fundamental constitutional rights must outweigh the necessity for prudence. The doctrine relating to constitutional issues of transcendental importance prevents courts from the paralysis of procedural niceties when clearly faced with the need for substantial protection.⁴¹ Notably, in Diocese of Bacolod, the Court brushed aside the COMELEC’s political question defense and held that “the concept of a political question…never precludes [a] judicial review when the act of a constitutional organ infringes upon a fundamental individual or collective right.”⁴² Thus, the Court had discernibly taken cognizance of the issues in Ong v. Senate of the Philippines,⁴³ In re Sabio,⁴⁴ and Standard Chartered Bank v. Senate Committee on Banks, Financial Institutions and Currencies,⁴⁵ wherein the constitutional rights of the resource persons—including the right to privacy, the right against self-incrimination, and the right to due process—were similarly asserted in opposition to the power of Congress to conduct inquiries in aid of legislation. Guo contends that the manner by which the hearings were conducted transgressed her fundamental rights to due process and privacy and that her continuous attendance would ostensibly subvert these basic rights.⁴⁶

The Court also finds that the fifth exception applies to the instant case. Time is of the essence herein, not only due to the grave accusations of impairment of Guo’s rights but also owing to the immediacy of the Senate Committee’s issuance of the order of arrest against Guo.⁴⁷ However, the Court notes that despite the order, Guo remains at large and has failed to submit herself to the Senate. Patently, the exigency of the situation requires immediate action and justifies direct resort to this Court.

The Court is not unmindful of the ruling in Gios-Samar, Inc. v. Department of Transportation and Communications,⁴⁸ where it decreed that, in determining whether direct resort to it shall be allowed, the decisive factor is not merely the presence of one or more of “special and important reasons,” but rather the nature of the question raised by the parties. Gios-Samar stressed that only controversies involving legal questions may be entertained at the first instance, such that when a question before the Court involves the determination of a factual issue indispensable to the resolution of the legal issue, the Court will refuse to resolve the question regardless of the allegation or invocation of compelling reasons, such as the transcendental or paramount importance of the case.⁴⁹

Even so, the Court finds that the issues raised by Guo in her Petition may be resolved through the application of well-settled constitutional principles relating to inquiries in aid of legislation. Thence, immediate recourse to the Court is warranted.

In ACT Teachers Representative Tinio v. President Duterte,⁵⁰ the Court pronounced that it may pass upon a controversy when its resolution may already be had through the application of well-settled constitutional or legal principles. In other words, “when there are no factual questions or when there are extant factual issues but they are not material to the constitutional issue that direct recourse to this Court under Section 5, Article VIII of the Constitution may be permitted.”⁵²

Guo bewails the violation of her constitutional rights in the course of the legislative inquiry. Following the doctrine laid down in ACT Teachers Representative Tinio, while the instant case involves the factual determination of whether the acts of the Senate Committee impaired Guo’s rights, at the core of the Petition is the authority of the Senate Committee to conduct the inquiry in aid of legislation. On this score, the Court highly esteems the authority of Congress or any of its committees to conduct inquiries in aid of legislation, in accordance with Article VI, Section 21⁵³ of the Constitution, and this shall be elaborated in the succeeding discussions.

The political question doctrine does not apply.
The Court takes cognizance of the case under
its expanded judicial power

Another impediment that the Senate Committee found in the Petition is that Guo seeks to have this Court resolve political questions or those “with regard to which full discretionary authority has been delegated to the legislature or executive branch of Government [and which] are beyond the pale of judicial review power.”⁵⁴

The Court is not convinced.

It bears stressing that the bedrock of the principle of non-justiciability of political questions is the principle of separation of powers, viz.:

Within its own sphere but only within such sphere each department is supreme and independent of the others, and each is devoid of authority not only to encroach upon the powers or field of action assigned to any of the other departments, but also to inquire into or pass upon the advisability or wisdom of the acts performed, measures taken or decisions made by the other departments provided that such acts, measures or decision are within the area allocated thereto by the Constitution.⁵⁵ (Emphasis in the original, citation omitted)

Conversely, an issue pertaining to whether constitutionally prescribed qualifications or conditions upon a grant of power have been met or the limitations thereto respected, is justiciable or non-political since the crux thereof is the legality or validity of the contested act, and not its wisdom.⁵⁶ Otherwise, said qualifications, conditions, or limitations particularly those prescribed by the Constitution would be set at naught.

In the seminal case of Tañada v. Angara,⁵⁷ the Court illumined that the petition seeking to nullify an act of the Senate on the ground that it contravenes the Constitution raises a justiciable controversy, thus:

Where an action of the legislative branch is seriously alleged to have infringed the Constitution, it becomes not only the right but in fact the duty of the [J]udiciary to settle the dispute. “The question thus posed is judicial rather than political. The duty (to adjudicate) remains to assure that the supremacy of the Constitution is upheld.” Once a “controversy as to the application or interpretation of a constitutional provision is raised before this Court (as in the instant case), it becomes a legal issue which the Court is bound by constitutional mandate to decide.”⁵⁸

Ineluctably, it is this Court’s bounden duty and power under Article VIII, Section 1⁵⁹ of the Constitution to determine whether or there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the government, including Congress. The Court will not shirk, digress from, or abandon its sacred duty and authority to uphold the Constitution in matters that involve grave abuse of discretion brought before it in appropriate cases committed by any officer, agency, instrumentality, or department of the government.⁶⁰

Appositely, Bengzon Jr. v. Senate Blue Ribbon Committee⁶¹ explicates that—

The “allocation of constitutional boundaries” is a task that this Court must perform under the Constitution. Moreover, as held in a recent case, “(t)he political question doctrine neither interposes an obstacle to judicial determination of the rival claims. The jurisdiction to delimit constitutional boundaries has been given to this Court. It cannot abdicate that obligation mandated by the 1987 Constitution, although said provision by no means does away with the applicability of the principle in appropriate cases.”

 

The Court is thus of the considered view that it has jurisdiction over the present controversy for the purpose of determining the scope and extent of the power of the Senate Blue Ribbon Committee to conduct inquiries into private affairs in purported aid of legislation.⁶²

Based on the foregoing jurisprudential touchstones and in light of the Court’s expanded power of judicial review, the Senate Committee cannot shield itself with the political question doctrine against the constitutional challenges vis-à-vis the conduct of its hearings. It is primal that the question as to whether any part or instrumentality of the government had authority or had abused its authority to the extent of lacking jurisdiction or exceeding jurisdiction is not a political question.⁶³

Having traversed these procedural matters, the Court shall now proceed to rule on the substantive issues raised in Guo’s Petition.

The Senate Committee’s conduct of the
inquiry is a valid exercise of
legislative power

Article VI, Section 21 of the Constitution empowers the Congress to conduct inquiries in aid of legislation—

SECTION 21. The Senate or 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.

Pertinently, Section 1 of the Senate Rules of Procedure Governing Inquiries in Aid of Legislation states:

SECTION 1. Power to Conduct Formal Inquiries or Investigations. The Senate or any of its Committees may conduct formal inquiries or investigations in aid of legislation in accordance with these Rules.

 

Such inquiries may refer to the implementation or re-examination of any law or appropriation, or in connection with any proposed legislation or the formulation of, or in connection with future legislation, or will aid in the review or formulation of a new legislative policy or enactment. They may also extend to any and all matters vested by the Constitution in Congress and/or in the Senate alone.

Time and again, the Court has affirmed the power of the legislature to conduct investigations. In Senate of the Philippines v. Executive Secretary Medialdea,⁶⁴ the Court explained the nature and purpose of inquiries in aid of legislation:

Inquiries in aid of legislation serve as tools to enable the legislative body to gather information and, thus, legislate wisely and effectively; and to determine whether there is a need to improve existing laws or enact new or remedial legislation, albeit the inquiry need not result in any potential legislation. To be within the jurisdiction of the legislative body making it, the inquiry must be material or necessary to the exercise of a power vested in it by the Constitution, such as to legislate or to expel a member.⁶⁵ (Emphasis in the original)

“The power of Congress to conduct inquiries in aid of legislation is inherent in its power to legislate.”⁶⁶ As early as the landmark case of Arnault v. Nazareno,⁶⁷ the Court decreed that the power of Congress to conduct investigations in aid of legislation did not need textual grant as it was implied and essential to the legislative function:

Although there is no provision in the Constitution expressly investing either House of Congress with power to make investigations and exact testimony to the end that it may exercise its legislative functions advisedly and effectively, such power is so far incidental to the legislative function as to be implied. In other words, the power of inquiry with process to enforce it is an essential and appropriate auxiliary to the legislative function.⁶⁸

In asserting that the Senate Committee gravely abused its discretion when it violated the Senate Rules and failed to observe the procedural and substantial limitations set by the Constitution in the conduct of its inquiry,⁶⁹ Guo posits that some of the questions propounded to her during the hearings conducted on May 7 and 22, 2024, were irrelevant to the proposed legislation meant to address the proliferation of human trafficking, torture, and cyber fraud operations in POGO. She was never asked about her duty to regulate the POGOs as the incumbent Mayor of Bamban.⁷⁰ Instead, “her personal life became the center of the inquiry, which [was] totally unrelated, unconnected, and unassociated with the pending resolutions subject of the public hearing. As a result, she was asked and forced to divulge matters of her private life, childhood, love life, and personal businesses to the public under the pain of contempt.”⁷¹

As underscored by Associate Justice Alfredo Benjamin S. Caguioa in his Concurring Opinion, the Court held in Arnault that the relevance of the questions asked during the inquiry should be assessed in relation to the subject of the inquiry, rather than the proposed legislation. In other words, it is not necessary for a question to be crucial to potential legislation. It is sufficient that the question is pertinent to the subject of the inquiry. The Court decreed, thusly—

Once an inquiry is admitted or established to be within the jurisdiction of a legislative body to make, we think the investigating committee has the power to require a witness to answer any question pertinent to that inquiry, subject of course to his constitutional right against self-incrimination. The inquiry, to be within the jurisdiction of the legislative body to make, must be material or necessary to the exercise of a power in it vested by the Constitution, such as to legislate, or to expel a Member; and every question which the investigator is empowered to coerce a witness to answer must be material or pertinent to the subject of the inquiry or investigation. So a witness may not be coerced to answer a question that obviously has no relation to the subject of the inquiry. But from this it does not follow that every question that may be propounded to a witness must be material to any proposed or possible legislation. In other words, the materiality of the question must be determined by its direct relation to the subject of the inquiry and not by its indirect relation to any proposed or possible legislation. The reason is, that the necessity or lack of necessity for legislative action and the form and character of the action itself are determined by the sum total of the information to be gathered as a result of the investigation, and not by a fraction of such information elicited from a single question.⁷² (Emphasis supplied)

Along this grain, Ong enunciates that inquiries into personal circumstances are not beyond the scope of legislative inquiry—

[P]ieces of information which relate to personal circumstances are not by themselves beyond the senate of legislative inquiry especially so where, as above stated, a contemplated legislation is being considered by the Congress.⁷³

In this case, the purpose of the Senate Committee’s inquiry is to aid Congress in crafting laws to counteract the proliferation of human trafficking, cyber fraud operations, serious illegal detention, physical abuse, and torture, and investigate the involvement of POGO operations in the commission of these crimes.⁷⁴

Guo’s name appeared in multiple documents connected with the illegal POGO operations of Zun Yuan Technology in Bamban, Tarlac.⁷⁵ She was identified as an incorporator and past president of Baofu, which owned the compound where Zun Yuan Technology’s offices were located. Upon thorough investigation, the DILG task force also found out that Guo was personally involved in the processing of clearances and permits for Baofu’s operations, prior to and even after assuming office as mayor of Bamban in 2022.⁷⁶ These findings further stirred queries pertaining to her identity, family history, relationships, connections, wealth, properties, and business interests. Such queries are not merely allowed, but also undisputedly necessary, as these are intimately related to the issues of whether she accumulated wealth in connection with the illegal POGO operations, whether her family is involved in the said operations, whether she took advantage of her public office and used her position and authority, and whether she has acquaintances in the government or private sector who are similarly involved in protecting these POGOs or who likewise accumulated wealth in connection with the illegal POGO operations.

Verily, Guo’s personal circumstances are central to the proceedings and are well within the Senate Committee’s scope of inquiry. Besides, questioning the wisdom of lawmakers in conducting their investigations would be akin to probing into their power to legislate.⁷⁷ The Court cannot interfere with the wisdom of the Senate Committee lest the sacred principle of separation of powers be unduly violated. On this score, the Court held in Senator Pangilinan v. Cayetano⁷⁸—

[T]he Courts will not normally interfere with the workings of another [coequal] branch unless the case shows a clear need for the courts to step in to uphold the law and the Constitution.⁷⁹ (Citation omitted)

The investigatory power of the legislative branch is given wide latitude. In the absence of information pertinent to a contemplated legislation, Congress will not be able to fully and effectively perform its function to conduct inquiries in aid of legislation.⁸⁰ Thence, so long as the inquiry is in accordance with the Senate’s rules of procedure and takes into account the rights of those affected or appearing thereat, the Court will not intrude into or interfere in the proceedings of the legislative branch in the legitimate exercise of its powers.

There was no violation of Guo’s
right to due process

Guo likens the Senate Committee hearings to a criminal trial, where she was “branded, called, and concluded to be a ‘liar,’ ‘spy,’ and ‘POGO operator” purportedly in violation of her right to due process. She invokes Article III, Section 14 or the Bill of Rights of the Constitution,⁸¹ which provides that:

Section 14. (1) No person shall be held to answer for a criminal offense without due process of law.

 

(2) In all criminal prosecutions, the accused shall be presumed innocent until the contrary is proved[.]

It bears emphasis that inquiries in aid of legislation are not criminal proceedings, but a sui generis constitutional power to ensure effective legislation.⁸² As the Court edifyingly elucidated in Romero II v. Senator Estrada⁸³—

A legislative investigation in aid of legislation and court proceedings has different purposes. On one hand, courts conduct hearings or like adjudicative procedures to settle, through the application of a law, actual controversies arising between adverse litigants and involving demandable rights. On the other hand, inquiries in aid of legislation are, inter alia, undertaken as tools to enable the legislative body to gather information and, thus, legislate wisely and effectively; and to determine whether there is a need to improve existing laws or enact new or remedial legislation, albeit the inquiry need not result in any potential legislation. On-going judicial proceedings do not preclude congressional hearings in aid of legislation.⁸⁴

Patently, in the Senate Committee’s hearings conducted on May 7 and 22, 2024, Guo was neither indicted as an accused in a criminal proceeding, nor did the Senate have the authority to convict her as a criminal. Rather, she was merely summoned and required to provide clear and honest responses as a resource person to aid in the legislative process. The issuance of the subpoena compelling her attendance in the public hearings, as well as the succeeding order of arrest⁸⁵ citing her in contempt was in accordance with the Senate Rules.

Besides, Guo was not unaware of the subject of the Senate Committee’s inquiry. In truth, the Senate Committee furnished her with copies of the measures to ensure that she was fully aware of the agenda.

In any event, Guo is accorded the privilege to invoke her right against self-incrimination during the proceedings—a right that she failed to exercise.⁸⁶ Henceforth, she cannot altogether decline appearing before the Senate on the ground that her right to due process was being violated.

There was no abuse of Guo’s
right to privacy

Guo laments that her birth certificate, SALNs, personal data sheet, NBI clearance, her corporations’ general information sheet, and details of her private personal life were released by the Senate to the media, resulting in the violation of her constitutional right to privacy.⁸⁷

Guo’s averment is out on a limb.

The right to privacy is enshrined in Article III, Section 3 or the Bill of Rights of the Constitution:

SECTION 3. (1) The privacy of communication and correspondence shall be inviolable except upon lawful order of the court, or when public safety or order requires otherwise as prescribed by law.

 

(2) Any evidence obtained in violation of this or the preceding section shall be inadmissible for any purpose in any proceeding.

Ople v. Torres⁸⁸ further elucidated that the right to privacy is protected in the other provisions, i.e., Sections 1, 2, 6, 8, and 17 of the Bill of Rights.

However, in Ayer Productions PTY. LTD. v. Hon. Capulong,⁸⁹ the Court had the occasion to rule that a public officer has a limited right to privacy when the information sought to be published about him or her constitutes matters of public character; thus, the right is not a defense against publication and dissemination of matters of public interest.⁹⁰

In Ayer, former Senator Juan Ponce Enrile (Enrile) refused to be included in a mini-television series entitled, “The Four[-]Day Revolution,” which tackled the EDSA Revolution. He applied for the issuance of a writ of preliminary injunction to enjoin the production of the mini-series, invoking his right to privacy. The Court ruled in favor of the production company, holding that Enrile’s major participation and role in the revolution could not be omitted from the mini-series; otherwise, it would be grossly unhistorical. In so ruling, the Court emphasized that Enrile continued to be a public figure whose right of privacy “is necessarily narrower than that of an ordinary citizen.”⁹¹

Ingeminating the Ayer doctrine, Ong instructs that the right to privacy is not absolute and cannot gain ascendancy over compelling state interest. In the said case, the Senate conducted an investigation in aid of legislation on the expenditures of the Department of Health during the COVID-19 pandemic. During the pendency of the investigation, the Senate ordered one of the petitioners, Michael Yang, to submit documents in relation to his income tax return, studies, and length of stay in the country, which he deemed to be beyond the scope of the inquiry and would violate his right to privacy. Yang then filed a petition for certiorari and prohibition before this Court. In striking down his arguments, the Court held that Yang’s right to privacy could not override the purpose of the inquiry to resolve the misuse of public funds in relation to the pandemic response.⁹²

In the present controversy, the Senate Committee’s public inquiry touches upon Guo’s degree of participation in relation to the illegal activities committed alongside POGO operations. In obeisance to Ayer and Ong, the Court, thus, holds that Guo, as the mayor of Bamban, has a limited expectation of privacy as an average citizen. The documents containing her personal information are deeply intertwined with the subject of the inquiry. Thus, she cannot simply invoke her right to privacy to prevent an inquiry into her personal information.

It also bears stressing that generally, inquiries in aid of legislation are public in nature, unless the Senate Committee, motu proprio or upon motion of any interested party, determines that the interrogation should be conducted in an executive session to protect national security.⁹³ This determination—whether to publicize or conduct the proceedings through an executive session—falls squarely within the Senate’s internal policy and generally beyond this Court’s power to review.

Besides, as heretofore adumbrated, the documents containing Guo’s personal information are inextricably interwoven with the subject of the inquiry. Her name appeared in multiple documents connected with the illegal POGO operations of Zun Yuan Technology in Bamban, Tarlac.⁹⁴ As more details from the DILG Task Force’s findings surfaced, questions arose about her identity, family history, relationships, connections, wealth, properties, and business interests. These findings, coupled with the discovery that members of her family and some of her acquaintances were involved in the POGO operations, and that the foreign nationals arrested within the Baofu compound, which she presumably owns, possessed Philippine passports and identification cards, effectively necessitate an inquiry into her personal circumstances.

Withal, Guo’s lack of consent to the release of her personal information does not violate her right to privacy. Rivetingly, she cannot seek refuge in Republic Act No. 10173 or the Data Privacy Act of 2012. Rule II, Sections 5(a)(1) and (d) of the Implementing Rules and Regulations (IRR) of Republic Act No. 10173 expressly clarified that the Act and the rules do not apply to “information processed for purpose of allowing public access to information that fall within matters of public concern” or those pertaining to “any individual who is or was an officer or employee of government that relates to his or her position or functions.” Similarly, the Act and its implementing rules do not apply to “information necessary in order to carry out the functions of public authority, in accordance with a constitutionally or statutorily mandated function pertaining to law enforcement or regulatory function.” Section 12(e) of Republic Act No. 10173 further states that the processing of personal information is permitted when its purpose is to “comply with the requirements of public order and safety or to fulfill functions of public authority.”

To recapitulate, the Senate Committee, pursuant to its constitutional mandate, is conducting an inquiry in aid of legislation to determine the extent of illegal operations within the POGOs and formulate laws to regulate or counteract the same. Guo is a public officer whose involvement in the POGOS is being questioned. As such, the public necessity of legislation preventing crimes and preserving public safety trumps the need for Guo’s consent to the discussion of the information contained in the documents.

This being so, the Court deems it necessary to iterate the following constitutional safeguards that proscribe the legislative power of inquiry:

One, it is imperative that the inquiry be done in accordance with the Senate’s duly published rules of procedure; and

Two, the rights of persons appearing in or affected by such inquiries must be respected in accordance with the Bill of Rights.⁹⁵ The goal of a legislative inquiry, in contrast to a court proceeding, is not to force an admission or a finding of guilt, but to ensure effective legislation.⁹⁶

Guo is not entitled to the issuance of a TRO
and/or writ of preliminary injunction

Finally, the Court denies Guo’s prayer for the issuance of a TRO and/or writ of preliminary injunction.

A writ of preliminary injunction may be granted if the following requisites are met: (1) the applicant must have a clear and unmistakable right, that is a right in esse; (2) there is a material and substantial invasion of such right; (3) there is an urgent need for the writ to prevent irreparable injury to the applicant; and (4) no other ordinary, speedy, and adequate remedy exists to prevent the infliction of irreparable injury.⁹⁷

To be entitled to an injunctive writ, the applicant must show that there exists a right to be protected which is directly threatened by an act sought to be enjoined.⁹⁸

Evidently, Guo miserably failed to discharge such burden. A perusal of her Petition reveals no clear showing of grave injustice or irreparable injury to her unless the prayer for injunctive relief is granted. With the passing of the July 10, 2024 hearing, and considering her absence therein, her prayer to prevent the Senate from requiring her to attend as a resource speaker on the matters and resolutions subject of the Subpoena Ad Testificandum dated July 1, 2024 has been rendered moot.⁹⁹

As for Guo’s prayer for the Court to issue an order directing the Senate Committee to desist from further inviting her to its hearings on the matters subject of the inquiry and the Senate resolutions, the same is also denied. In refusing to attend the subsequent hearings, Guo argues that these shall likewise violate her constitutional rights to due process and privacy. Clearly, her argument is highly speculative. As earlier discussed, the Court finds no violation of her rights to due process and privacy during the May 7 and 22, 2024 hearings. She, or even this Court, has nary a basis to predict or presume that the Senate’s line of questioning for the subsequent hearings would violate her constitutional rights. This being so, the prayer for the issuance of injunctive relief ought to be denied.

The contempt orders issued
by the Senate are valid

Concomitant to the power of the Legislature to conduct inquiries in aid of legislation is its power of contempt impliedly provided under the Constitution. This coercive process is essential to the Legislature’s discharge of its functions. This power permits either House of the Legislature to perform its duties without impediment, as it enables the Senate or the House of Representatives to legislate wisely or effectively because they have the power to compel the availability of information necessary in shaping legislation.¹⁰⁰

Being wholly ancillary to the power to investigate, the contempt power of the Legislature is sui generis and allows it to punish contumacious acts against it (such as a witness’s refusal to be sworn, testify, answer a proper question, appear, or bring required documents).¹⁰¹ Moreover, by citing a person in contempt, the Legislature asserts its authority as one of the three independent and coordinate branches of government.¹⁰²

It bears stressing that in citing a resource person for contempt, the Legislature only needs to show that it has a clear, factual basis for such determination.¹⁰³ Here, clear and factual bases were shown—first, Guo left the Philippines despite due notice, prompting the issuance of the first contempt order; and second, she refused to respond even to the simplest of questions propounded by the senators during the September 9, 2024 hearing, prompting the issuance of the second contempt order. Consequently, the Court will respect the Senate’s finding, consistent with the esteem accorded to a coequal branch of government and the sui generis character of legislative contempt.

ACCORDINGLY, the Petition for Certiorari is DISMISSED and the application for issuance of a temporary restraining order and/or writ of preliminary injunction and the Omnibus Motion to lift the contempt orders dated July 11, 2024 and September 9, 2024 are DENIED.

SO ORDERED.