Arnault v. Balagtas G.R. No.

L-6749 | 1955-07-30 Issue: Did the Senate believe the statement of the petitioner in his statement that the recipient of the P440,000 is Jess D. Santos? And if so, is the court authorized to review the same? If the Senate did not believe the statement, is the continued confinement of petitioner pursuant to Senate Resolution of Nov. 8, 1952 valid? Facts: Jean L. Arnault (petitioner) was the attorney in the negotiations for the purchase of Buenavista and Tambobong Estates by the Government of the Philippines. The purchase was effected and the price was P5,000,000. Consequently, the Senate adopted Resolution No. 8 creating a committee tasked to investigate on the said purchase particularly on its validity and honesty. In the course of investigation, herein petitioner was asked to whom a certain price (P440,000), was delivered. Upon failing to answer such question, he was committed to the custody of the Sergeant at arms of the Phil. Senate and imprisoned in the new Bilibid Prison in Rizal until such time when he shall be willing to disclose the identity of the recipient and answer relevant questions. While being held at the Bilibid, petitioner issued an affidavit stating the events surrounding the acquisition of the Estates by Gen. Burt, under which circumstances he came across one Jess D. Santos. Herein petitioner was then questioned regarding the identity of Jess D. Santos and the investigation produced Resolution No. 114 on Nov. 8, 1952 directing the director of prison to continue the confinement of Arnault on the following grounds: Petitioner has failed and continues to fail and refuse to disclose the identity of the recipient of P440,000. He continuously acts in contempt in his withholding of the information and untruthful statements in his affidavit and the power of the Senate has been disregarded due to his defiance. The information, which the petitioner contumaciously holds, is necessary for the discharge of legislative functions. Thus, petitioner filed for a writ of habeas corpus in the CFI alleging that: The deal was not illegal, in fact beneficial to the Government. That the decision of the court in his imprisonment was beyond limitations. That he should be held in contempt when in fact he disclosed the identity of the recipient in the person of Jess D. Santos. That the Senate is not justified in finding the petitioner did tell the truth when he mentioned Jess D. Santos specially on the basis of evidence. That the condition attached to his confinement was accomplished therefore, continuous confinement is no longer needed. Held: The judgment appealed from is reversed. Petition for the issuance of the writ of habeas corpus is denied. Order of the court allowing the petitioner to give bail is declared null and void and petitioner is hereby recommitted to the custody of the respondent. Costs against petitioner. Ratio: 1st Issue The conclusion of the Senate Committee in not believing petitioners affidavit was not based on the evidence given and the Senate abused its discretion in making its conclusion.

The lower court erred in assuming that it has the right to review the findings made by the legislative bodies known as legislative process. This would constitute a direct violation of the Constitutional mandate of separation of powers. The only instances when judicial intervention may be appreciated are times when there has been a violation of a constitutional inhibition. In the absence of a clear violation of a constitutional inhibition, the courts should assume that legislative discretion has been properly exercised. All the courts may do is to make sure that due process has been given to the petitioner of due process, which was duly extended to him. nd 2 Issue Senate found that the petitioner did not disclose the identity of the recipient by the mere stating of Jess D. Santos. The Senate has the power to commit a witness who refuses to answer a question pertinent to a legislative inquiry to compel his participation thru coercive power and not its punitive power. American legislative bodies, to which our own is patterned have the power to punish for contempt if the contempt has had the effect of preventing it from exercising its functions. The power to punish for a past contempt is an appropriate means. This power is implied or incidental to legislative power and necessary to exercise such power. The legislative cannot exercise its legitimate authority if it is hindered by every act of refusal, defiance and contumacy of defiant witnesses. Nor can it be accepted that the legislative must resort to the judiciary in said times due to its incompetence caused by said hindrances.