GR L 6749; (July, 1955) (Digest)
G.R. No. L-6749 July 30, 1955
JEAN L. ARNAULT, petitioner-appellee, vs. EUSTAQUIO BALAGTAS, as Director of Prisons, respondent-appellant.
FACTS
Petitioner Jean L. Arnault was the attorney-in-fact for Ernest H. Burt in the government’s purchase of the Buenavista and Tambobong Estates. The Senate created a Special Committee to investigate the deal. During the investigation, Arnault was asked to reveal the name of the person to whom a portion of the purchase price, P440,000, was delivered. He refused to answer, leading the Senate on May 15, 1950, to order his imprisonment for contempt until he revealed the name. This order was upheld by the Supreme Court in a prior case (G.R. No. L-3820). While imprisoned, Arnault executed an affidavit naming “Jess D. Santos” as the recipient. The Senate Committee, after further questioning, found this disclosure unsatisfactory and, on November 8, 1952, adopted Resolution No. 114, ordering his continued detention for failing to purge himself of contempt. Arnault then filed a petition for habeas corpus in the Court of First Instance of Rizal, which granted his release, declaring his continued detention illegal. The Director of Prisons appealed this decision.
ISSUE
1. Whether the courts may review the Senate Committee’s factual finding that Arnault failed to truthfully reveal the name of the person who received the P440,000.
2. Whether Arnault’s continued detention under Senate Resolution No. 114 is valid.
RULING
The Supreme Court reversed the judgment of the Court of First Instance and denied the petition for habeas corpus.
1. The courts cannot review the factual findings of a legislative body in the exercise of its legislative investigative power. The Senate Committee’s determination that Arnault’s answer (naming Jess D. Santos) was untruthful and constituted a continuing refusal to answer is within its discretion and not subject to judicial review. The lower court erred in arrogating to itself the power to examine the evidence and conclude that Arnault had satisfactorily proven the existence of Jess D. Santos.
2. Arnault’s continued detention is valid. His act of providing a name the Senate found to be false did not purge him of contempt; it was a repetition of the offense and an affront to the Senate’s dignity. The detention remains coercive in nature, intended to compel disclosure of the required information. The period of imprisonment did not exceed legal limits for punitive contempt, as the November 1952 resolution was for a new and continuing contempt. The Senate’s power to detain for contempt, upheld as coercive rather than punitive, persists until the demanded information is truthfully provided. The order granting Arnault bail was declared null and void, and he was ordered recommitted to custody.