GR 34361; (November, 1930) (Digest)

G.R. No. 34361, November 5, 1930
CANDIDO B. LOPEZ, petitioner-appellant, vs. JOSE DE LOS REYES, in his capacity as Peace Officer and Assistant Chief of the Constabulary, respondent-appellee.

FACTS

On October 23, 1929, Candido B. Lopez allegedly assaulted Representative Jose D. Dimayuga while the latter was on his way to attend a session of the House of Representatives. The House, after a hearing where Lopez was given an opportunity to defend himself, adopted a resolution on November 6, 1929, finding Lopez guilty of contempt for violating the privileges of a member and ordering his confinement in Bilibid Prison for 24 hours. The warrant of arrest was not served before the House adjourned its second session on November 8, 1929. On September 16, 1930, during its third session, the House adopted a confirmatory resolution and issued a new warrant. Lopez was arrested on September 19, 1930, pursuant to this warrant. He filed a petition for habeas corpus, arguing that the House lacked jurisdiction to punish him for an assault, which is a judicial matter, and that its power to punish for contempt ceased upon the adjournment of the 1929 session.

ISSUE

1. Does the House of Representatives have the power to punish for contempt an act committed against one of its members?
2. Does the power to punish for contempt continue beyond the session during which the contempt was committed?

RULING

1. Yes. The House of Representatives possesses the inherent power to punish for contempt acts that obstruct or impede its legislative functions or violate its privileges. The assault on a member while proceeding to a session constitutes a contempt of the House, as it directly interferes with the performance of legislative duties. This power is essential for self-preservation and the effective exercise of legislative authority, and it is not an encroachment on judicial power because it pertains to the legislative body’s own dignity and efficiency.

2. Yes. The power to punish for contempt persists beyond the session during which the contempt was committed, provided the legislative body itself has not finally adjourned sine die (i.e., terminated its existence). The adjournment on November 8, 1929, was merely a recess between sessions of the same legislature. The House remained the same entity and retained its authority to enforce its contempt order during its subsequent session in 1930. The confirmatory resolution and new warrant were valid exercises of this continuing power.

The Court affirmed the dismissal of the habeas corpus petition and upheld the detention of Lopez under the House’s order. The legislative power to punish for contempt is a necessary attribute of a coordinate branch of government, and the judiciary cannot interfere with its lawful exercise absent a clear showing of excess of jurisdiction or grave abuse of discretion.