At the height of Garci Tape, Fertilizer Fund Scam and North Rail Project investigation by Senate, former Pres. GMA simply thwarted all the invitations for aid of legislation by issuing an EO 464. After the heat died down, and after more than 6 months, the SC decision was rendered invalidating certain Sections of EO 464 and upholding the Legislative Power of Inquiry at all times.
I wonder why the decision comes with no "sanction" for the blatant disregard of GMA Administration? It becomes easy now that should any sitting President encounters "heat" from co-equal branch, an issuance of EO464-like and an interpretation after 6months will save his hide.