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ARNAULT VS NAZARENO

Inquiry in Aid of Legislation


This case arose from the legislative inquiry into the acquisition by the Philippine Government of the
Buenavista and Tambobong estates sometime in 1949. Among the witnesses called to be examined
by the special committee created by a Senate resolution was Jean L. Arnault, a lawyer who
delivered a partial of the purchase price to a representative of the vendor. During the Senate
investigation, Arnault refused to reveal the identity of said representative, at the same time invoking
his constitutional right against self-incrimination. The Senate adopted a resolution committing Arnault
to the custody of the Sergeant-at-Arms and imprisoned until he shall have purged the contempt by
revealing to the Senate . . . the name of the person to whom he gave the P440,000, as well as
answer other pertinent questions in connection therewith. Arnault petitioned for a writ of Habeas
Corpus
ISSUE: Can the senate impose penalty against those who refuse to answer its questions in a
congressional hearing in aid of legislation.
HELD: It is the inherent right of the Senate to impose penalty in carrying out their duty to
conduct inquiry in aid of legislation. But it must be herein established that a witness who refuses to
answer a query by the Committee may be detained during the term of the members imposing said
penalty but the detention should not be too long as to violate the witness right to due process of law.

BENGZON VS SEN BLUE RIBBON COMMITTEE
203 SCRA 767 Political Law Constitutional Law The Legislative Department Inquiry in Aid of
Legislation When not Allowed
It was alleged that Benjamin Kokoy Romualdez and his wife together with the Marcoses unlawfully
and unjustly enriched themselves at the expense of the Filipino people. That they obtained with the
help of the Bengzon Law Office and Ricardo Lopa Corys brother in law, among others, control
over some of the biggest business enterprises in the country including MERALCO, PCI Bank, Shell
Philippines and Benguet ConsolidatedMining Corporation.
Senator Juan Ponce Enrile subsequently delivered a privilege speech alleging that Lopa took over
various government owned corporations which is in violation of the Anti-Graft and Corrupt Practices
Act. Contained in the speech is a motion to investigate on the matter. The motion was referred to the
Committee on Accountability of Public Officers or the Blue Ribbon Committee. After committee
hearing, Lopa refused to testify before the committee for it may unduly prejudice a pending civil case
against him. Bengzon likewise refused invoking his right to due process. Lopa however sent a letter
to Enrile categorically denying his allegations and that his allegations are baseless and malicious.
Enrile subsequently took advantage of the Senates privilege hour upon which he insisted to have
an inquiryregarding the matter. The SBRC rejected Lopas and Bengzons plea.
Claiming that the Senate Blue Ribbon Committee is poised to subpoena them and require their
attendance and testimony in proceedings before the Committee, in excess of its jurisdiction and
legislative purpose, in clear and blatant disregard of their constitutional rights, and to their grave and
irreparable damage, prejudice and injury, and that there is no appeal nor any other plain, speedy
and adequate remedy in the ordinary course of law, Bengzon et al filed a petition for prohibition with
a prayer for temporary restraining order and/or injunctive relief against the SBRC.
ISSUE: Whether or not the inquiry sought by the SBRC be granted.
HELD: No, the inquiry cannot be given due course. The speech of Enrile contained no suggestion of
contemplated legislation; he merely called upon the Senate to look into a possible violation of Sec. 5
of RA No. 3019, otherwise known as The Anti-Graft and Corrupt Practices Act. In other words, the
purpose of the inquiryto be conducted by the Blue Ribbon Committee was to find out whether or not
the relatives of Cory, particularly Lopa, had violated the law in connection with the alleged sale of the
36 or 39 corporations belonging to Kokoy to the Lopa Group. There appears to be, therefore, no
intended legislation involved. Hence, the contemplatedinquiry by the SBRC is not really in aid of
legislation because it is not related to a purpose within the jurisdiction of Congress, since the aim of
the investigation is to find out whether or not the relatives of the President or Mr. Ricardo Lopa had
violated Section 5 of RA No. 3019, the Anti-Graft and Corrupt Practices Act, a matter that appears
more within the province of the courts rather than of the legislature. Besides, the Court may take
judicial notice that Mr. Ricardo Lopa died during the pendency of this case.

SENATE VS ERMITA

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