See - http://sc.judiciary.gov.ph/pdf/web/viewer.html?file=/jurisprudence/2018/march2018/223451.pdf
Sen. Trillanes IV vs. Hon. Castillo-Marigomen, GR 223451, March 14, 2018:
"Petitioner admits that he uttered the questioned statements, describing private respondent as former VP Binay's "front" or "dummy" in connection with the so-called Hacienda Binay, in response to media interviews during gaps and breaks in plenary and committee hearings in the Senate. 44 With Jimenez as our guidepost, it is evident that petitioner'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 petitioner's 40 duties as a Senator, as the remarks were not part of or integral to the legislative process. "
SC.JUDICIARY.GOV.PH
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