DIGEST/KAY MARIE BOLANDO/JEAN N. ARNAULT VS. ESTAQUIO BALAGTAS

Jean L. Arnault vs. Eustaquio Balagtas, as Director of Prisons

GR No. L-6749, July 30, 1955

FACTS:

    Petitioner-appellee was an attorney in-fact or Ernest H. Burt in the negotiations for the purchase of the Buenavista and Tambobong Estates by the Government of the Philippines. The purchase effected on October 21, 1949 for the price of both estatesP5,000,000.

    On February 27, 1950, the Senate of the Philippines adopted Resolution No. 8 whereby it created a Special Committee to determine "whether the said purchase was honest, valid and proper and whether the price involved in the deal was fair and just, the parties responsible therefor, any other facts the Committee may deem proper in the premises"

    In the investigation, the Committee asked petitioner-appellee to whom a part of the purchase price or P400,000 was delivered. The latter refused to answer the question, whereupon the Committee resolved on to order his commitment to the custody of the Sergeant-at-arms of the Philippines Senate and imprisoned in the new Bilibid Prison in Rizal until such time when he shall reveal to the Senate or to the Special Committee the name of the person who received the P440,000 and to answer questions pertinent thereto.

    Petitioner-appellee questioned the validity of the confinement so ordered, by a petition for certiorari. He contended that the Senate of the Philippines has no power to punish him for contempt for refusing to reveal the name of the person to whom he delivered the money and that the Legislature lacks authority to punish him for contempt beyond the term of the legislative session and that the question of the Senate which he refused to answer is an incriminating question which the appellee is not bound to answer.

The Court denied his petition for release.

Petitioner-appellee petition for the writ of habeas corpus in the Court of First Instance alleges:

   

     (1) That the acquisition by the Government, through the Rural Progress Administration, of the Buenavista and Tambobong Estates was not illegal nor irregular nor scandalous nor malodorous, but was in fact beneficial to the Government;

    (2) That the decision of this Court in GR No. L-3820 declared that the Senate did not imprison Arnault "beyond proper limitations", beyond the period longer than arresto mayor, as this is the maximum penalty that can be imposed under the provisions of Art. 150 of RPC;

    (3) That petitioner-appellee purged himself of the contempt charges when he disclosed the fact that the one to whom he gave the P440,000 was Jess D. Santos, and submitted evidence in corroboration thereof;

    (4) That the Senate is not justified in finding that the petitioner-appellee did tell the truth when he mentioned Jess D. Santos as the person whom he gave the P440,000, specially on the basis of the evidence submitted to it;

    (5) that the Legislative purpose or intention, for which the Senate ordered the confinement may be considered as having been accomplished, and therefore, there is no reason for petitioner-appellee's continued confinement.

ISSUE:

    Whether or not the continued confinement and detention of the petitioner-appellee, as ordered in Senate Resolution, valid?

RULING:

    The Court held that the claim that the purchase of the Buenavista and Tambobong Estates is beneficial to the government and is neither illegal nor irregular.

    A study of the text of the resolution readily shows that the Senate found that the petitioner-appellee did not disclose, by the mere giving of the name Jess D. Santos, the identity of the person to whom the sum of P440,000 was delivered and in addition thereto that petitioner withheld said identity arrogantly and contumaciously in continued affront of the Senate's authority and dignity.

    The principle that Congress or any of its bodies has the power to punish recalcitrant witnesses is founded upon reason and policy. The said power must be considered implied or incidental to the exercise of legislative power, or necessary to effectuate said power.

    

    The process by which a contumacious witness is dealt with by legislature in order to enable it to exercise its legislative power or authority must be distinguished from the judicial process by which offenders are brought to the courts of justice for the meting of the punishment which the criminal law imposes upon them. The former falls exclusively within the legislative authority, the latter within the domain of the courts; because the former is a necessary concomitant of the legislative power or process, while the latter has to do with the enforcement and application of the criminal law.

    The Court also held that contempt is related to the exercise of the legislative power and is committed in the course of the legislative process, the legislature's authority to deal with the defiant and contumacious witness should be supreme, and unless there is a manifest and absolute disregard of discretion and a mere exertion of arbitrary power coming within the reach of constitutional limitations, the exercise of the authority is not subject to judicial interference.

    Hence, the judgment appealed from should be 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.