The presiding officer referred to Duterte v. House while stating the limited purpose for which subpoenaed records could be used.
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July 20, 2026
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Duterte v. House of Representatives, G.R. Nos. 278353 and 278359 (July 25, 2025)
Supreme Court resolution
Presidential Decree No. 1792 amending Republic Act No. 1405
Statute
The presiding officer discussed the bank-deposit confidentiality rule and its impeachment exception while resolving the subpoena requests.
Republic of the Philippines (AMLC) v. Sandiganbayan and Office of the Ombudsman, G.R. Nos. 232724-27 (February 15, 2021)
Supreme Court decision
The presiding officer cited the decision for the relevance and definiteness requirements for a subpoena duces tecum, and later in addressing the Anti-Money Laundering Council subpoena.
BSB Group, Inc. v. Sally Go, G.R. No. 168644 (February 16, 2010)
Supreme Court decision
The presiding officer cited BSB Group in explaining the relevance standard applied to the requested records.
Apostol v. Lubigan-Rafael, G.R. No. 260640 (October 1, 2025)
Supreme Court decision
The presiding officer cited Apostol in explaining that the subpoena process may not be used for a fishing expedition.
Concerned Taxpayer v. Doblada Jr., A.M. No. P-99-1342 (June 8, 2005)
Supreme Court decision
The presiding officer cited the decision while explaining why records from the earlier period could establish a baseline for comparing lawful income and assets.
Office of the Ombudsman v. Arnel A. Bernardo, G.R. No. 181598 (March 6, 2013)
Supreme Court decision
The presiding officer referred to Bernardo in discussing the relevance of a public officer's beginning net worth to a comparison of later assets and income.
Subido Pagente Certeza Mendoza and Binay Law Offices v. Court of Appeals, G.R. No. 216914 (December 6, 2016)
Supreme Court decision
The presiding officer invoked the decision while reserving that Carpio Lawyers and affected clients could pursue appropriate remedies concerning specific privileged material.