DIGEST/ LINALYN BATION/ JEAN L. ARNAULT vs LEON NAZARENO, Sergeant-at-arms, Philippine Senate, and EUSTAQUIO BALAGTAS, Director of Prisons

G.R. No. L-3820             July 18, 1950

JEAN L. ARNAULT, petitioner,
vs.
LEON NAZARENO, Sergeant-at-arms, Philippine Senate, and EUSTAQUIO BALAGTAS, Director of Prisons, respondents.

 

FACTS:

          The Philippine Government, through the Rural Progress Administration, bought two estates known as Buenavista and Tambobong for P4.5M and P0.5M respectively, or for an aggregate amount of P5M.  P1.5M of which was paid to Ernest H. Burt, a nonresident American, supposedly as payment for his interest in the two aforementioned estates. Jean L. Arnault, Burt's representative in the Philippines, collected the sum of P1.5M in the form of checks and encashed P400,000, which he eventually gave to an undisclosed person as per Burt's instructions.

          However, that these transactions were dubious in nature. For one, both estates were already owned by the Philippine Government, so there was no need to repurchase them for P5M. Second, Burt's interest in both estates amounted to only P20,000, which he wasn't even entitled to because of his failure to pay off his previous loans. 

          In a Senate investigation which was thereafter held, one of the issues pursued was to whom did Arnault give the cash amounting to P400,000. Arnault's refusal to provide the name of the person, initially because he couldn't remember it and later for fear of self-incrimination, led to his being cited for contempt. He was thereafter held in prison, and was to be freed only after saying the name of the person he gave the P400,000 to. 

          Subsequently, Arnault filed this instant petition for habeas corpus in an apparent bid to be freed from imprisonment. 

 

ISSUE:

          Whether or not the Senate has the power to punish Arnault for contempt

 

RULING:

          Yes. The Senate has the power to punish Arnault for contempt. Once an inquiry is admitted or established to be within the jurisdiction of a legislative body to make, the investigating committee has the power to require a witness to answer any question pertinent to that inquiry, subject of course to his constitutional right against self-incrimination. The inquiry, to be within the jurisdiction of the legislative body to make, must be material or necessary to the exercise of a power in it vested by the Constitution. So, a witness may not be coerced to answer a question that obviously has no relation to the subject of the inquiry. But from this it does not follow that every question that may be propounded to a witness must be material to any proposed or possible legislation. In other words, the materiality of the question must be determined by its direct relation to any proposed or possible legislation. The reason is, that the necessity or lack of necessity for legislative action and the form and character of the action itself are determined by the sum total of the information to be gathered as a result of the investigation, and not by a fraction of such information elicited from a single question.