Arnault vs Balagtas (1955)

Arnault vs Balagtas (1955) G.R. No. L-6749 Subject: Rule on Non-interference between Independent Branches of Governent! "ontept #ower of the Le$islature! "ontept power is iplied or incidental to the e%erci e%ercise se of le$isl le$islati ative ve power! power! #ower #ower of le$isl le$islatu ature re to punish punish for past past conte contept! pt! &iscretion to lift contept Facts' Facts' (ean L. )rnault was an attorne* in-fact of +rnest ,. Burt in the ne$otiations for the purchase of the Buenavista and abobon$ +states b* the #hilippine Governent. he price paid for both estates was # /illion. 0ubse1uent*2 the 0enate of the #hilippines adopted Resolution No. 32 whereb* it created a 0pecial "oittee to investi$ate the purchase transaction. &urin$ said investi$ation2 )rnault was ased to who a part of the purchase price2 or #44525552 was delivered. )rnault refused to answer this 1uestion2 whereupon the "oittee resolved to order his coitent to the custod* of the 0er$eant at-ars of the #hilippines 0enate and iprisoned in the new Bilibid #rison in Rial until such tie when he shall reveal to the 0enate or to the 0pecial "oittee the nae of the person person who who receiv received ed the #4452 #4452555 555 and to answe answerr 1uesti 1uestions ons pertin pertinent ent theret thereto. o. )rnault 1uestioned the validit* of the confineent order via a petition for certiorari filed in this "ourt. ,e contended that the 0enate of the #hilippines has no power to punish hi for contept for refusin$ to reveal the nae of the person2 that the Le$isl Le$islatu ature re lacs lacs author authorit* it* to punish punish hi for contept contept be*ond be*ond the ter of the le$islative session2 and that the 1uestion of the 0enate which he refused to answer is an incriinatin$ 1uestion which he is not bound to answer. he petition was denied. hile still in confineent in Bilibid2 )rnault e%ecuted an affidavit detailin$ the events surroundin$ the ac1uisition of the Buenavista and abobon$ +states b* Gen. Burt2 and the circustances under which he et one b* the nae of (ess &. 0antos. 8pon the presentation of the said affidavit to the said 0enate 0pecial "oittee2 the latter subected petitioner to 1uestionin$ re$ardin$ the identit* of (ess &. 0antos. ,owever2 $iven the persistent withholdin$ b* )rnault of the identit* of the person who received the #4452555 in connection with the Buenavista and abobon$ estates deal2 the 0enate ordered his continued confineent in Bilbid . )rnault sou$ht relief b* filin$ a petition for the writ of habeas corpus in the ":I of  Rial. ,e claied that he had pur$ed hiself of the contept char$es when he disclosed the fact that the one to who he $ave the #4452555 was (ess &. 0antos2 and subitted evidence in corroboration thereof. he ":I of Rial declared that the continued detention of )rnault has becoe ille$al in view of the disclosures he has alread* $iven2 i.e.2 nain$ (ess &. 0antos as the receiver of the #4452555. Held' Held' Rule on Non-intererence Non-intererence bet!een "nde#endent Branc$es o %overn&ent ;. It is evident that the the 0enate "oittee did not believe )rnault 6. )ll that the courts a* do2 in relation to the proceedin$s taen a$ainst petitioner prior to his incarceration2 is to deterine if the constitutional $uarantee of due process has been accorded hi before his incarceration b* le$islative order2 and this because of the andate of the 0upree Law of the land that no an shall be deprived life2 libert* or propert* without due process of law. In the case at bar such ri$ht has full* been e%tended the petitioner =)rnault>2 he havin$ been $iven the opportunit* to be heard personall* and b* counsel in all the proceedin$s prior to the approval of the Resolution orderin$ his continued confineent. 'onte&#t o!er o t$e egislature 7. he te%t of the resolution readil* shows that the 0enate found that )rnault did

not disclose2 b* the ere $ivin$ of the nae (ess &. 0antos2 the identit* of the person to who the su of #4452555 was delivered2 and that )rnault withheld said identit* arro$antl* and contuaciousl* in continued affront of the 0enate
coitted in the course of the le$islative process2 the le$islature