Carmelo v. Ramos

Summary

This case established the principle that committees created by municipal mayors lack the inherent power to issue subpoenas and compel witness attendance. The Supreme Court ruled that while mayors have implied investigative powers over city employees, such powers cannot be delegated to committees without express statutory authority to take testimony. The Court emphasized that Rule 64 contempt proceedings apply only to judicial bodies, not administrative ones, unless specifically provided by law. The decision protects citizens from compulsory process by administrative bodies lacking proper legal authority, reinforcing the distinction between judicial and administrative powers and safeguarding due process rights in administrative investigations.