Trillanes v. Marigomen Case Digest
G.R. No. 223451. March 14, 2018 
 

FACTS:

Senator Trillanes filed a senate resolution directing an investigation, in aid of legislation, of the reported overpricing of the Makati City Hall II Parking Building and related anomalies. Trillanes alleged that during Senate Blue Ribbon Sub-Committee (SBRS) hearing, former Makati Vice Mayor Mercado testified that he helped VP Binay acquire 350-hectare estate in Batangas. During media interviews at the Senate, particularly during gaps and breaks in the plenary and committee hearings, Trillanes stated that based on his office's review of the documents, Antonio Tiu appears to be Binay's dummy. Tiu thus filed a complaint for damages against Trillanes. Trillanes filed a motion to dismiss invoking parliamentary immunity. 


ISSUE:

Were the statements of Trillanes covered by parliamentary immunity?


RULING:

Trillanes's remarks fall outside the privilege of speech or debate under Section 11, Article VI of the 1987 Constitution. The statements were clearly not part of any speech delivered in the Senate or any of its committees. They were also not spoken in the course of any debate in said fora. It cannot likewise be successfully contended that they were made in the official discharge or performance of Trillanes' duties as a Senator, as the remarks were not part of or integral to the legislative process.

Parliamentary non-accountability cannot be invoked when the lawmaker's speech or utterance is made outside sessions, hearings or debates in Congress, extraneous to the "due functioning of the (legislative) process." To participate in or respond to media interviews is not an official function of any lawmaker; it is not demanded by his sworn duty nor is it a component of the process of enacting laws. Indeed, a lawmaker may well be able to discharge his duties and legislate without having to communicate with the press. A lawmaker's participation in media interviews is not a legislative act, but is "political in nature," outside the ambit of the immunity conferred under the Speech or Debate Clause in the 1987 Constitution. Contrary to Trillane's stance, therefore, he cannot invoke parliamentary immunity to cause the dismissal of private respondent's Complaint. The privilege arises not because the statement is made by a lawmaker, but because it is uttered in furtherance of legislation.

The parliamentary non-accountability granted to members of Congress is not to protect them against prosecutions for their own benefit, but to enable them, as the people's representatives, to perform the functions of their office without fear of being made responsible before the courts or other forums outside the congressional hall.