ARNAULT vs.

BALAGTAS
Citation: G.R. No. L-6749; 97 Phil. 358; July 30, 1955
Ponente: Labrador

Topic: Legislative investigation; may Senate hold a person in contempt as a punitive

measure.

FACTS:
This was a petition for habeas corpus filed by Jean Arnault against the Director of Prisons,
Balagtas. Arnault was incarcerated pursuant to a resolution by the Senate finding Arnault
in contempt for refusing to disclose the name of a person with whom he transacted
business in relation to a government purchase of of the Buenavista and Tambobong
estates. The circumstances of Arnault's incarceration are described in the companion
case Arnaultvs. Nazareno (1950) which affirmed the Legislature's power to hold a person
in contempt for defying or refusing to comply with an order in a legislative inquiry.

Arnault eventually divulged that he had transacted with one Jess D. Santos in relation to
the Buenavista and Tambobong deal. Upon further inquiry, the Senate, obviously not
satisfied with Arnault's explanations, adopted Resolution No. 114. The title of the
resolution states:

RESOLUTION APPROVING THE REPORT OF THE SPECIAL COMMITTEE TO

INVESTIGATE THE BUENAVISTA AND TAMBOBONG ESTATES DEAL, AND
ORDERING THE DIRECTOR OF PRISON TO CONTINUE HOLDING JEAN L.
ARNAULT IN HIS CUSTODY, AND IN CONFINEMENT AND DETENTION AT THE NEW
BILIBID PRISON AT MUNTINLUPA, RIZAL, UNTIL THE SAID ARNAULT SHALL HAVE
PURGED HIMSELF OF CONTEMPT OF THE SENATE.

xxx

WHEREAS, the Senate holds and finds that the situation of the said Jean L. Arnault has
not materially changed since he was committed to prison for contempt of the Senate, and
since the Supreme Court of the Philippines, in a judgment long since become final, upheld
the power and authority of the Senate to hold the said Jean L. Arnault in custody,
detention, and confinement, said power and authority having been held to be coercive
rather than punitive, and fully justified until the said Jean L. Arnault should have given the
information which he had withheld and continues contumaciously to withhold;

WHEREAS, the insolent and manifest untruthful statements made by the said Jean L.
Arnault on the occasions above referred to constitute a continuing contempt of the
Senate, and an added affront to its dignity and authority, such that , were they to be
condoned or overlooked, the power and authority of the Senate to conduct investigations
would become futile and ineffectual because they could be defied by any person of
sufficient stubbornness and malice;

xxx

The Court of First Instance ruled in favor of Petitioner Arnault and ordered his release.

ISSUE:
Whether or not Petitioner may be released from his Senate-imposed incarceration.
1. Whether or not the CFI has the right to review the findings of the Senate.

2. Whether or not the Senate may hold a person in contempt or incarcerate him as a
punitive rather than as a coercive measure.

HELD:
YES. The Senate may continue to keep Petitioner incarcerated.

1. NO. In the first place, the CFI did NOT have the right to review the findings of the
Senate. In the above quoted resolution, the Senate in stating that petitioner “has failed
and refused, and continues to fail and refuse, to reveal the person to whom he gave the
amount of P440,000” and that the situation of petitioner “has not materially charged since
he was committed to prison”, clearly shows that the Senate believes that Arnault was still
trying to deceive them. The CFI on the other hand arrogated unto itself to review such
finding and held that Arnault satisfactorily answered the questions of the Senate in its
investigation of the Buenavista and Tambobong deal.

There is an inherent fundamental error in the course of action that the lower court
followed. It assumed that courts have the right to review the findings of legislative bodies
in the exercise of the prerogative of legislation, or interfere with their proceedings or their
discretion in what is known as the legislative process. The Judicial department has no
right or power or authority to do this, in the same manner that the legislative department
may not invade the judicial realm in the ascertainment of truth and in the application and
interpretation of the law, in what is known as the judicial process, because that would be
in direct conflict with the fundamental principle of separation of powers established by the
Constitution. The only instances when judicial intervention may lawfully be invoke
are when there has been a violation of a constitutional inhibition, or when there has
been an arbitrary exercise of the legislative discretion.

2. YES. The legislature may hold a person in contempt or incarcerate him as a punitive
measure.

Although the resolution studiously avoids saying that the confinement is a punishment,
but merely seeks to coerce the petitioner into telling the truth, the intention is evident that
the continuation of the imprisonment ordered is in fact partly punitive. This may be inferred
from the confining made in the resolution that petitioner's acts were arrogant and
contumacious and constituted an affront to the Senate's dignity and authority.

The legislature has the power to punish recalcitrant witnesses. This power is founded
upon reason and policy. Said power must be considered implied or incidental to the
exercise of legislative power, or necessary to effectuate said power. How could a
legislative body obtain the knowledge and information on which to base intended
legislation if it cannot require and compel the disclosure of such knowledge and
information, if it is impotent to punish a defiance of its power and authority? The legislative
department should not be constrained to look to the courts whenever for every act of
refusal, every act of defiance, every act of contumacy with which it is faced.

The exercise of the legislature's authority to deal with the defiant and contumacious
witness should be supreme and is not subject to judicial interference, except when there
is a manifest and absolute disregard of discretion and a mere exertion of arbitrary power
coming within the reach of constitutional limitations.
The judgment appealed from should be, as it hereby is, reversed, and the petition for the
issuance of the writ of habeas corpus denied. The order of the court allowing the
petitioner to give bail is declared null and void and the petitioner is hereby ordered to be
recommitted to the custody of the respondent. With cost against the petitioner-appellee.