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.

x x x

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;

x x x

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.