63.calida Vs Trillanes GR. No. 240873
63.calida Vs Trillanes GR. No. 240873
63.calida Vs Trillanes GR. No. 240873
Yes. The legislative power to conduct investigations in aid of legislation is conferred by Article
VI, Section 21 of the 1987 Constitution, which provides:
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.
No matter how noble the intentions of respondent Committees are, they cannot assume the
power reposed upon our prosecutorial bodies and courts. The determination of who is/are
liable for a crime or illegal activity, the investigation of the role played by each official, the
determination of who should be haled to court for prosecution, and the task of coming up with
conclusions and finding of facts regarding anomalies, especially the determination of criminal
guilt, are not functions of the Senate. Congress is neither a law enforcement nor a trial agency.
Moreover, it bears stressing that no inquiry is an end in itself; it must be related to, and in
furtherance of, a legitimate task of the Congress, i.e., legislation. Investigations conducted
solely to gather incriminatory evidence and "punish" those investigated are indefensible. There
is no Congressional power to expose for the sake of exposure.
This Court's power of judicial review is limited to an actual case and controversy. An actual case
and controversy exist when there is a conflict of legal rights or opposite legal claims capable of
judicial resolution and specific relief. The controversy must be real and substantial and must
require a specific relief that courts can grant.
This Court also takes judicial notice that respondent Trillanes has reached the end of his two-
year term as senator. Thus, the petitioners' prayer for this Court to permanently prohibit him
from conducting an investigation into their supposed conflict of interest has likewise been
rendered moot.