July 18, 1950 | 87 Phil. 29
Jean L. Arnault, petitioner
Leon Nazareno in his capacity as Seargant-at-Arms of the Philippine Senate and Eustaqio Balagtas in his capacity as Director of Prisons, respondents
FACTS:
In October 1949, 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. Of this sum, P1.5M was paid to Ernest H. Burt, a nonresident American, supposedly as payment for his interest in the two aforementioned estates. Jean L. Arnaut, Burt's representative in the Philippines, collected the sum of P1.5M in the form of checks. From this amount, he encashed P400,000, which he eventually gave to an undisclosed person as per Burt's instructions.
It turned out, 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.
A Senate investigation was thereafter held to determine how the Philippine Government was duped and who ultimately benefited from the assailed transaction. 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.
ISSUES:
1. Whether or not the Senate has the power to punish Arnault for contempt.
2. Whether or not the Senate can impose punishment beyond the legislative session.
3. Whether or not Arnault can invoke the right against self-incrimination as an excuse in not answering the question he is being asked in the Senate.
Before delving into the issues at hand, the Court laid down some general principles of law:
- The Philippine Constitution is patterned after the US Constitution. But despite similarities in the basic structure of government, one essential difference is that the Philippine legislative department is more powerful than its US counterpart, in the sense that the latter shares power with the congresses of individual states.
- The power of inquiry -- with process to enforce it -- is an essential and appropriate auxiliary to the legislative function of the Philippine congress. Although there are no express provisions in the constitution that invest either the House or the Senate with the power to conduct investigations and exact testimony, such power is implied.
1. Yes, the Court ruled that such power is necessary, especially in the conduct of inquiries that fall within the Senate's jurisdiction (see [b] above). With this in mind, it is not a requirement that each and every single question asked of witnesses necessarily be material to the case. This is so because 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.
2. In the instant case, the resolution holding Arnault for contempt was issued on May 15, 1950. He was subsequently detained for 13 days, or beyond the legislative session of Congress, which session ended on May 18 of the same year. Arnault claimed that his continued detention had no legal basis, since the body that issued the resolution had already been dissolved by law. But the Court ruled that the Senate is a continuing body and does not cease to exist upon the periodical dissolution of the Congress. As such, there is no time limit to the Senate's power to punish for contempt in cases where that power may be constitutionally exerted.
3. No, the Court held that Arnault's invocation of the right against self-incrimination has no basis. Arnault failed in discharging his duty of providing frank, sincere, and truthful testimony before a competent authority -- a violation of the State's right to exact fulfillment of a citizen's obligation. When a specific right and a specific obligation conflict with each other, and one is doubtful or uncertain while the other is clear and imperative, the former must give way to the latter.
PETITION FOR HABEAS CORPUS DISMISSED.