Professional Documents
Culture Documents
RAUL DAZA VS. LUIS SINGSON GUINGONA VS. GONZALES (October 20, 1992)
Tribunal and its Composition FACTS: After the May 11, 1992 elections, the senate was composed of 15 LDP
The Laban ng Demokratikong Pilipino (LDP) was reorganized resulting to a senators, 5 NPC senators, 3 LAKAS-NUCD senators, and 1 LP-PDP-LABAN
political realignment in the lower house. LDP also changed its representation senator. To suffice the requirement that each house must have 12
in the Commission on Appointments. They withdrew the seat occupied by representatives in the CoA, the parties agreed to use the traditional formula:
Daza (LDP member) and gave it to the new LDP member. Thereafter the (No. of Senators of a political party) x 12 seats) Total No. of Senators
chamber elected a new set of representatives in the CoA which consisted of elected. The results of such a formula would produce 7.5 members for LDP,
the original members except Daza who was replaced by Singson. Daza 2.5 members for NPC, 1.5 members for LAKAS-NUCD, and 0.5 member for LP-
questioned such replacement. PDP-LABAN. Romulo, as the majority floor leader, nominated 8 senators from
ISSUE: Whether or not a change resulting from a political realignment validly their party because he rounded off 7.5 to 8 and that Taada from LP-PDP-
changes the composition of the Commission on Appointments. LABAN should represent the same party to the CoA. This is also pursuant to
HELD: As provided in the constitution, there should be a Commission on the proposition compromise by Sen Tolentino who proposed that the elected
Appointments consisting of twelve Senators and twelve members of the members of the CoA should consist of eight LDP, one LP-PDP-LABAN, two NPC
House of Representatives elected by each House respectively on the basis of and one LAKAS-NUCD. Guingona, a member of LAKAS-NUCD, opposed the
proportional representation of the political parties therein, this necessarily said compromise. He alleged that the compromise is against proportional
connotes the authority of each house of Congress to see to it that the representation.
requirement is duly complied with. Therefore, it may take appropriate
measures, not only upon the initial organization of the Commission but also ISSUE: Whether or not rounding off is allowed in determining a partys
subsequently thereto NOT the court. representation in the CoA.
CUNANAN VS. TAN DISCUSSION: It is a fact accepted by all such parties that each of them is
5 SCRA 1 (1962) entitled to a fractional membership on the basis of the rule on proportional
FACTS: Petitioner sought to nullify the ad interim appointment of Jorge Tan representation of each of the political parties. A literal interpretation of
Jr as acting Deputy Administrator of the Reforestation Administration. Carlos Section 18 of Article VI of the Constitution leads to no other manner of
Cunanan was formerly appointed in the same position but was later application. The problem is what to do with the fraction of .5 or 1/2 to which
on rejected by the Commision of Appointment prompting the President to each of the parties is entitled. The LDP majority in the Senate converted a
replace him with Jorge Tan Jr immediately without his consent. Filing the quo fractional half membership into a whole membership of one senator by
adding one half or .5 to 7.5 to be able to elect Romulo. In so doing one other Held: The respondents claim to membership in the CA by nomination and
partys fractional membership was correspondingly reduced leaving the election of the LDP majority in the Senate is not in accordance with Sec. 18 of
latters representation in the Commission on Appointments to less than their Art. VI of the Constitution and therefore violative of the same because it is
proportional representation in the Senate. This is clearly a violation of Section not in compliance with the requirement that 12 senators shall be elected on
18 because it is no longer in compliance with its mandate that membership the basis of proportional representation of the political parties represented
in the Commission be based on the proportional representation of the therein. To disturb the resulting fractional membership of the political parties
political parties. The election of Senator Romulo gave more representation to in the CA by adding together 2 halves to make a whole is a breach of the rule
the LDP and reduced the representation of one political party either the on proportional representation because it will give the LDP an added member
LAKAS NUCD or the NPC. A party should have at least 1 seat for every 2 duly in the CA by utilizing the fractional membership of the minority political party,
elected senators-members in the CoA. Where there are more than 2 parties who is deprived of half a representation. The provision of Sec. 18 on
in Senate, a party which has only one member senator cannot constitutionally proportional representation is mandatory in character and does not leave any
claim a seat. In order to resolve such, the parties may coalesce with each discretion to the majority party in the Senate to disobey or disregard the rule
other in order to come up with proportional representation especially since on proportional representation.
one party may have affiliations with the other party.
The Constitution does not require that the full complement of 12 senators be
RULING: elected to the membership in the CA before it can discharge its functions and
In the light of the foregoing and on the basis of the applicable rules and that it is not mandatory to elect 12 senators to the CA. The overriding
jurisprudence on the matter before this Court, We declare the election of directive of Art. VI, Sec. 18 is that there must be a proportional representation
Senator Alberto Romulo and Senator Wigberto Taada as members of the of the political parties in the membership of the CA and that the specification
Commission on Appointments as null and void for being in violation of the of 12 members to constitute its membership is merely an indication of the
rule on proportional representation under Section 18 of Article VI of the 1987 maximum complement allowable under the Constitution. The act of filling up
Constitution of the Philippines. Accordingly, a writ of prohibition is hereby the membership thereof cannot disregard the mandate of proportional
issued ordering the said respondents Senator Romulo and Senator Taada to representation of the parties even if it results in fractional membership in
desist from assuming, occupying and discharging the functions of members unusual situations. Even if the composition of the CA is fixed by the
of the Commission on Appointments; and ordering the respondents Senate Constitution, it can perform its functions even if not fully constituted, so long
President Neptali Gonzales, in his capacity as ex-officio Chairman of the as it has the required quorum.
Commission on Appointments, to desist from recognizing the membership of
the respondent Senators and from allowing and permitting them from sitting ARNAULT VS. NAZARENO
and participating as members of said Commission Inquiry in Aid of Legislation
This case arose from the legislative inquiry into the acquisition by the
GUINGONA VS. GONZALES (March 1, 1993) Philippine Government of the Buenavista and Tambobong estates sometime
Facts: The mathematical representation of each of the political parties in 1949. Among the witnesses called to be examined by the special
represented in the Senate for the Commission on Appointments (CA) is as committee created by a Senate resolution was Jean L. Arnault, a lawyer who
follows: LDP7.5; LP-PDP-LABAN--.5; NPC2.5; LAKAS-NUCD1.5. The LDP delivered a partial of the purchase price to a representative of the vendor.
majority in the Senate converted a fractional half membership into a whole During the Senate investigation, Arnault refused to reveal the identity of said
membership of one Senator by adding one-half or .5 to 7.5 to be able to elect representative, at the same time invoking his constitutional right against self-
respondent Senator Romulo. In so doing, one other partys fractional incrimination. The Senate adopted a resolution committing Arnault to the
membership was correspondingly reduced leaving the latters representation custody of the Sergeant-at-Arms and imprisoned until he shall have purged
in the CA to less than their proportional representation in the Senate. the contempt by revealing to the Senate . . . the name of the person to whom
Issue: Whether or not there is a violation of Art. VI, Sec. 18
he gave the P440,000, as well as answer other pertinent questions in intended to satisfy the basic requirements of due process. Publication is
connection therewith. Arnault petitioned for a writ of Habeas Corpus indeed imperative, for it will be the height of injustice to punish or otherwise
ISSUE: Can the senate impose penalty against those who refuse to answer its burden a citizen for the transgression of a law or rule of which he had no
questions in a congressional hearing in aid of legislation. notice whatsoever, not even a constructive one. What constitutes publication
HELD: It is the inherent right of the Senate to impose penalty in carrying out is set forth in Article 2 of the Civil Code, which provides that [l]aws shall take
their duty to conduct inquiry in aid of legislation. But it must be herein effect after 15 days following the completion of their publication either in the
established that a witness who refuses to answer a query by the Committee Official Gazette, or in a newspaper of general circulation in the Philippines.
may be detained during the term of the members imposing said penalty but
the detention should not be too long as to violate the witness right to due The Senate admits in their pleadings and even on oral argument that the
process of law. Senate Rules of Procedure Governing Inquiries in Aid of Legislation had been
published in newspapers of general circulation only in 1995 and in 2006. With
VIRGILIO GARCILLANO VS. HOUSE OF REPRESENTATIVES COMMITTEES ON respect to the present Senate of the 14th Congress, however, of which the
PUBLIC INFORMATION term of half of its members commenced on June 30, 2007, no effort was
Inquiry in Aid of Legislation Senate Rules of Procedure undertaken for the publication of these rules when they first opened their
In 2005, tapes which allegedly contained a conversation between GMA and session.
COMELEC Commissioner Garcillano surfaced. The said conversation
contained a plan to rig the elections to favor GMA. The recordings then SPOUSES PNP DIRECTOR ELISEO AND MARIA FE DELA PAZ VS. SENATE
became subject to legislative hearings conducted separately by each House. COMMITTEE ON FOREIGN AFFAIRS
In his privilege speech, Sen. Escudero motioned a congressional investigation Inquiry in Aid of Legislation Jurisdiction and Publication
jointly conducted by the Committees on Public Information, Public Order and In October 2008, Gen. De La Paz, a senior officer of the PNP, headed a
Safety, National Defense and Security, Information and Communications delegation of 8 to attend an Interpol GA. De La Paz brought with him his wife
Technology, and Suffrage and Electoral Reforms (respondent House and 3 days after the scheduled GA, de la Paz is also scheduled to retire. After
Committees). During the inquiry, several versions of the wiretapped the GA, De La Paz was apprehended in the departure area for he was carrying
conversation emerged. Lacsons motion for a senate inquiry was referred to with him 105,000.00 (P6,930,000.00). He was also carrying with him
the Committee on National Defense and Security headed by Biazon. Garci 45,000.00 (P2,970,000.00). He failed to declare in writing that he is carrying
subsequently filed to petitions. One to prevent the playing of the tapes in the such an amount and this is in violation of the United Nations Convention
each house for they are alleged to be inadmi8ssible and the other to prohibit Against Corruption and the United Nations Convention Against Transnational
and stop the conduct of the Senate inquiry on the wiretapped conversation. Organized Crime. De La Paz and his group was later released but the s were
ISSUE: Whether or not to grant the petitions of Garci. confiscated by the Russians. Upon arrival to the Philippines, De La Paz was
HELD: Garcis petition to strike the tapes off the record cannot be granted. issued a subpoena by the Senate Committee on Foreign Relations for the
The tapes were already played in Congress and those tapes were already investigation it was to conduct involving the Moscow incident. De La Paz
highly publicized. The issue is already overtaken by these incidents hence it averred that the said committee does not have jurisdiction of the case. De La
has become moot and academic. The second petition must be granted Paz argued that the Committee is devoid of any jurisdiction to investigate the
however. The Senate cannot be allowed to continue with the conduct of the Moscow incident as the matter does not involve state to state relations as
questioned legislative inquiry without duly published rules of procedure, in provided in paragraph 12, Section 13, Rule 10 of the Senate Rules of
clear derogation of the constitutional requirement. Procedure (Senate Rules). They further claim that respondent Committee
Section 21, Article VI of the 1987 Constitution explicitly provides that [t]he violated the same Senate Rules when it issued the warrant of arrest without
Senate or the House of Representatives, or any of its respective committees the required signatures of the majority of the members of respondent
may conduct inquiries in aid of legislation in accordance with its duly Committee. They likewise assail the very same Senate Rules because the
published rules of procedure. The requisite of publication of the rules is same were not published as required by the Constitution, and thus, cannot
be used as the basis of any investigation involving them relative to the the National Security Adviser are covered by the executive privilege; and Such
Moscow incident. other officers as may be determined by the President, from appearing in such
ISSUE: Whether or not the said Committee has jurisdiction over the matter. hearings conducted by Congress without first securing the presidents
HELD: The SC ruled against De La Paz. Section 16(3), Article VI of the approval.
Philippine Constitution states:Each House shall determine the rules of its The department heads and the military officers who were invited by
proceedings. This provision has been traditionally construed as a grant of full the Senate committee then invoked EO 464 to except themselves. Despite EO
discretionary authority to the Houses of Congress in the formulation, 464, the scheduled hearing proceeded with only 2 military personnel
adoption and promulgation of its own rules. The challenge to the jurisdiction attending. For defying President Arroyos order barring military personnel
of the Senate Foreign Relations Committee, raised by petitioner in the case from testifying before legislative inquiries without her approval, Brig. Gen.
at bench, in effect, asks this Court to inquire into a matter that is within the Gudani and Col. Balutan were relieved from their military posts and were
full discretion of the Senate. The issue partakes of the nature of a political made to face court martial proceedings. EO 464s constitutionality was
question. Also, the signatures were properly obtained as evidenced by the assailed for it is alleged that it infringes on the rights and duties of Congress
approval of the Senate president and it is shown that the gathering of the to conduct investigation in aid of legislation and conduct oversight functions
signatures is in accordance with the Rules. It is also shown that the Rules of in the implementation of laws.
Procedure Governing Inquiries in Aid of Legislation were also published in two ISSUE: Whether or not EO 464 is constitutional.
newspapers of general circulation. HELD: The SC ruled that EO 464 is constitutional in part. To determine the
validity of the provisions of EO 464, the SC sought to distinguish Section 21
SENATE OF THE PHILIPPINES VS. EXEC. SEC. EDUARDO ERMITA from Section 22 of Art 6 of the 1987 Constitution. The Congress power of
495 SCRA 170 Political Law Constitutional Law Legislative Branch inquiry is expressly recognized in Section 21 of Article VI of the Constitution.
Question Hour Constitutionality of E.O. 464 Although there is no provision in the Constitution expressly investing either
FACTS: In 2005, scandals involving anomalous transactions about the North House of Congress with power to make investigations and exact testimony to
Rail Project as well as the Garci tapes surfaced. This prompted the Senate to the end that it may exercise its legislative functions advisedly and effectively,
conduct a public hearing to investigate the said anomalies particularly the such power is so far incidental to the legislative function as to be implied. In
alleged overpricing in the NRP. The investigating Senate committee issued other words, the power of inquiry with process to enforce it is an essential
invitations to certain department heads and military officials to speak before and appropriate auxiliary to the legislative function. A legislative body cannot
the committee as resource persons. Ermita submitted that he and some of legislate wisely or effectively in the absence of information respecting the
the department heads cannot attend the said hearing due to pressing matters conditions which the legislation is intended to affect or change; and where
that need immediate attention. AFP Chief of Staff Senga likewise sent a the legislative body does not itself possess the requisite information which
similar letter. Drilon, the senate president, wrote that the Senators are is not infrequently true recourse must be had to others who do possess it.
unable to accede the said requests for they were sent belatedly and Section 22 on the other hand provides for the Question Hour. The
arrangements were already made and scheduled. Subsequently, GMA issued Question Hour is closely related with the legislative power, and it is precisely
EO 464 which took effect immediately. as a complement to or a supplement of the Legislative Inquiry. The
EO 464 basically prohibited Department heads, Senior officials of appearance of the members of Cabinet would be very, very essential not only
executive departments who in the judgment of the department heads are in the application of check and balance but also, in effect, in aid of legislation.
covered by the executive privilege; Generals and flag officers of the Armed Section 22 refers only to Question Hour, whereas, Section 21 would refer
Forces of the Philippines and such other officers who in the judgment of the specifically to inquiries in aid of legislation, under which anybody for that
Chief of Staff are covered by the executive privilege; Philippine National matter, may be summoned and if he refuses, he can be held in contempt of
Police (PNP) officers with rank of chief superintendent or higher and such the House. A distinction was thus made between inquiries in aid of legislation
other officers who in the judgment of the Chief of the PNP are covered by the and the question hour. While attendance was meant to be discretionary in
executive privilege; Senior national security officials who in the judgment of the question hour, it was compulsory in inquiries in aid of legislation. Sections
21 and 22, therefore, while closely related and complementary to each other, BENGZON JR. VS. SENATE BLUE RIBBON COMMITTEE
should not be considered as pertaining to the same power of Congress. One 203 SCRA 767 Political Law Constitutional Law The Legislative
specifically relates to the power to conduct inquiries in aid of legislation, the Department Inquiry in Aid of Legislation When not Allowed
aim of which is to elicit information that may be used for legislation, while FACTS: It was alleged that Benjamin Kokoy Romualdez and his wife
the other pertains to the power to conduct a question hour, the objective of together with the Marcoses unlawfully and unjustly enriched themselves at
which is to obtain information in pursuit of Congress oversight the expense of the Filipino people. That they obtained with the help of the
function. Ultimately, the power of Congress to compel the appearance of Bengzon Law Office and Ricardo Lopa Corys brother in law, among others,
executive officials under Section 21 and the lack of it under Section 22 find control over some of the biggest business enterprises in the country including
their basis in the principle of separation of powers. MERALCO, PCI Bank, Shell Philippines and Benguet Consolidated Mining
While the executive branch is a co-equal branch of the legislature, it Corporation.
cannot frustrate the power of Congress to legislate by refusing to comply with Senator Juan Ponce Enrile subsequently delivered a privilege speech alleging
its demands for information. When Congress exercises its power of inquiry, that Lopa took over various government owned corporations which is in
the only way for department heads to exempt themselves therefrom is by a violation of the Anti-Graft and Corrupt Practices Act. Contained in the speech
valid claim of privilege. They are not exempt by the mere fact that they are is a motion to investigate on the matter. The motion was referred to the
department heads. Only one executive official may be exempted from this Committee on Accountability of Public Officers or the Blue Ribbon
power the President on whom executive power is vested, hence, beyond Committee. After committee hearing, Lopa refused to testify before the
the reach of Congress except through the power of impeachment. It is based committee for it may unduly prejudice a pending civil case against him.
on her being the highest official of the executive branch, and the due respect Bengzon likewise refused invoking his right to due process. Lopa however
accorded to a co-equal branch of government which is sanctioned by a long- sent a letter to Enrile categorically denying his allegations and that his
standing custom. The requirement then to secure presidential consent allegations are baseless and malicious.
under Section 1, limited as it is only to appearances in the question hour, is Enrile subsequently took advantage of the Senates privilege hour
valid on its face. For under Section 22, Article VI of the Constitution, the upon which he insisted to have an inquiry regarding the matter. The SBRC
appearance of department heads in the question hour is discretionary on rejected Lopas and Bengzons plea.
their part. Section 1 cannot, however, be applied to appearances of Claiming that the Senate Blue Ribbon Committee is poised to
department heads in inquiries in aid of legislation. Congress is not bound in subpoena them and require their attendance and testimony in proceedings
such instances to respect the refusal of the department head to appear in before the Committee, in excess of its jurisdiction and legislative purpose, in
such inquiry, unless a valid claim of privilege is subsequently made, either by clear and blatant disregard of their constitutional rights, and to their grave
the President herself or by the Executive Secretary. and irreparable damage, prejudice and injury, and that there is no appeal nor
When Congress merely seeks to be informed on how department any other plain, speedy and adequate remedy in the ordinary course of law,
heads are implementing the statutes which it has issued, its right to such Bengzon et al filed a petition for prohibition with a prayer for temporary
information is not as imperative as that of the President to whom, as Chief restraining order and/or injunctive relief against the SBRC.
Executive, such department heads must give a report of their performance as ISSUE: Whether or not the inquiry sought by the SBRC be granted.
a matter of duty. In such instances, Section 22, in keeping with the separation HELD: No, the inquiry cannot be given due course. The speech of Enrile
of powers, states that Congress may only request their appearance. contained no suggestion of contemplated legislation; he merely called upon
Nonetheless, when the inquiry in which Congress requires their appearance the Senate to look into a possible violation of Sec. 5 of RA No. 3019, otherwise
is in aid of legislation under Section 21, the appearance is mandatory for the known as The Anti-Graft and Corrupt Practices Act. In other words, the
same reasons stated in Arnault. purpose of the inquiry to be conducted by the Blue Ribbon Committee was
to find out whether or not the relatives of Cory, particularly Lopa, had
violated the law in connection with the alleged sale of the 36 or 39
corporations belonging to Kokoy to the Lopa Group. There appears to be,
therefore, no intended legislation involved. Hence, the contemplated inquiry He later refused to attend the other hearings and Ermita sent a letter to the
by the SBRC is not really in aid of legislation because it is not related to a senate averring that the communications between GMA and Neri are
purpose within the jurisdiction of Congress, since the aim of the investigation privileged and that the jurisprudence laid down in Senate vs Ermita be
is to find out whether or not the relatives of the President or Mr. Ricardo Lopa applied. He was cited in contempt of respondent committees and an order
had violated Section 5 of RA No. 3019, the Anti-Graft and Corrupt Practices for his arrest and detention until such time that he would appear and give his
Act, a matter that appears more within the province of the courts rather testimony.
than of the legislature. Besides, the Court may take judicial notice that Mr.
ISSUE: Are the communications elicited by the subject three (3) questions
Ricardo Lopa died during the pendency of this case.
covered by executive privilege?
ROMULO NERI VS. SENATE COMMITTEES ON ACCOUNTABILITY OF PUBLIC HELD: The communications are covered by executive privilege.
OFFICERS AND INVESTIGATIONS, SENATE COMMITTEE ON TRADE AND The revocation of EO 464 (advised executive officials and employees
COMMERCE, AND SENATE COMMITTEE ON NATIONAL DEFENSE AND to follow and abide by the Constitution, existing laws and jurisprudence,
SECURITY including, among others, the case of Senate v. Ermita when they are invited
G.R. No. 180643, March 25, 2008 to legislative inquiries in aid of legislation.), does not in any way diminish the
concept of executive privilege. This is because this concept has Constitutional
FACTS: On April 21, 2007, the Department of Transportation and underpinnings.
Communication (DOTC) entered into a contract with Zhong Xing The claim of executive privilege is highly recognized in cases where
Telecommunications Equipment (ZTE) for the supply of equipment and the subject of inquiry relates to a power textually committed by the
services for the National Broadband Network (NBN) Project in the amount of Constitution to the President, such as the area of military and foreign
U.S. $ 329,481,290 (approximately P16 Billion Pesos). The Project was to be relations. Under our Constitution, the President is the repository of the
financed by the Peoples Republic of China. commander-in-chief, appointing, pardoning, and diplomatic powers.
The Senate passed various resolutions relative to the NBN deal. In the Consistent with the doctrine of separation of powers, the information
September 18, 2007 hearing Jose de Venecia III testified that several high relating to these powers may enjoy greater confidentiality than others.
executive officials and power brokers were using their influence to push the Several jurisprudence cited provide the elements of presidential
approval of the NBN Project by the NEDA. communications privilege:
Neri, the head of NEDA, was then invited to testify before the Senate Blue 1) The protected communication must relate to a quintessential and non-
Ribbon. He appeared in one hearing wherein he was interrogated for 11 hrs delegable presidential power.
and during which he admitted that Abalos of COMELEC tried to bribe him with 2) The communication must be authored or solicited and received by a
P200M in exchange for his approval of the NBN project. He further narrated close advisor of the President or the President himself. The judicial test is that
that he informed President Arroyo about the bribery attempt and that she an advisor must be in operational proximity with the President.
instructed him not to accept the bribe. 3) The presidential communications privilege remains a qualified privilege
However, when probed further on what they discussed about the that may be overcome by a showing of adequate need, such that the
NBN Project, petitioner refused to answer, invoking executive privilege. In information sought likely contains important evidence and by the
particular, he refused to answer the questions on: unavailability of the information elsewhere by an appropriate investigating
(a) whether or not President Arroyo followed up the NBN Project, authority.
(b) whether or not she directed him to prioritize it, and
(c) whether or not she directed him to approve. In the case at bar, Executive Secretary Ermita premised his claim of
executive privilege on the ground that the communications elicited by the
three (3) questions fall under conversation and correspondence between
the President and public officials necessary in her executive and policy
decision-making process and, that the information sought to be disclosed
might impair our diplomatic as well as economic relations with the Peoples
Republic of China. Simply put, the bases are presidential communications
privilege and executive privilege on matters relating to diplomacy or foreign
relations.
Using the above elements, we are convinced that, indeed, the
communications elicited by the three (3) questions are covered by the
presidential communications privilege. First, the communications relate to a
quintessential and non-delegable power of the President, i.e. the power to
enter into an executive agreement with other countries. This authority of the
President to enter into executive agreements without the concurrence of the
Legislature has traditionally been recognized in Philippine jurisprudence.
Second, the communications are received by a close advisor of the
President. Under the operational proximity test, petitioner can be
considered a close advisor, being a member of President Arroyos cabinet.
And third, there is no adequate showing of a compelling need that would
justify the limitation of the privilege and of the unavailability of the
information elsewhere by an appropriate investigating authority.
Respondent Committees further contend that the grant of
petitioners claim of executive privilege violates the constitutional provisions
on the right of the people to information on matters of public concern.50 We
might have agreed with such contention if petitioner did not appear before
them at all. But petitioner made himself available to them during the
September 26 hearing, where he was questioned for eleven (11) hours. Not
only that, he expressly manifested his willingness to answer more questions
from the Senators, with the exception only of those covered by his claim of
executive privilege.
The right to public information, like any other right, is subject to
limitation. Section 7 of Article III provides:
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 law.