Arnault v. Balagtas etc. (aka Arnault v. Nazareno II?

)
July 30, 1955
Labrador, J.
PETITIONER and APPELLEE
Jean L. Arnault
RESPONDENT and APPELLANT
Eustaquio Balagtas (as Director of Prisons)
NATURE
Appeal from a judgment of the CFI of Rizal, Pasay City Branch
BRIEF
a witness was committed to prison for failing to provide the name of a person linked to an anomalous land transaction
that was being investigated by Congress. This is one time when we can pine for the old days in relation to a certain
government official who refuses to answer certain questions of the Senate, invoking executive privilege. Later on he
provided a name but the Congress was not satisfied that it was the correct one and he remained incarcerated
(ARNAULT vs. BALAGTAS, G.R. No. L-6749. July 30, 1955). He was literally damned if he did and damned if didnt.
And only the truth, or what is perceived to be the truth, could set him free. FACTS

Doctrine: The findings and machinations in a legislative inquiry are outside the jurisdiction of
the courts.
Facts:
The incarcerated Arnault finally gave in and signed an affidavit stating the name of the person
he gave the P440k check to. Consequently, he thinks he can go free and thus filed a petition to
have his sentence lifted.
The Court of First Instance acknowledged it and granted his freedom on the grounds that the
Senate committed a clear abuse of discretion in considering his answer naming Jess D. Santos.
Issue:
Was it valid for the judiciary to review the findings of legislative bodies in their exercise
of the prerogative of legislation, or interfere with their proceedings or their discretion in
what is known as the legislative process? No.
Ratio:
According to the separation of powers, this inquiry is purely within the jurisdiction of the
legislature and any interference thereof is unconstitutional. The judicial department of
government has no right or power or authority to do, much in the same manner that the
legislative department may not invade the judicial realm in the ascertainment of the 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.

Arnault files a petition for release from the custody of the Senate because he has (1)
answered the question the Senate wanted clearing him of contempt and (2) served the
sentence of his previous contempt case.
Doctrine: Power of investigation includes the power to punish a witness. Judiciary has no
right to encroach on legislative inquiries unless there has been a violation of a constitutional
inhibition,or an arbitrary exercise of the legislative discretion.
Note: Materiality of question determined by its direct relation to the subject of inquiry and
not by its indirect relation to any proposed or possible legislation.

ISSUES x RULING
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YES/NO.ENTER RULING DISCUSSION TEXT HERE ENTER RULING DISCUSSION TEXT HERE
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LAW/PROVISION or CASE CITED: Enter here provisions in law or decision in case

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DISCUSSION HERE ENTER FURTHER DISCUSSION HEREENTER FURTHER DISCUSSION HERE
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DISPOSITIVE
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OPINIONS
1

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2

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