G.R. No. L-3820 – 87 Phil. 29 – Political Law – Constitutional Law – Legislative Branch – Powers of the Legislature – Inquiry in Aid of Legislation
This case arose from the legislative inquiry into the acquisition by the Philippine Government of the Buenavista and Tambobong estates sometime in 1949. Among the witnesses called to be examined by the special committee created by a Senate resolution was Jean L. Arnault, a lawyer who delivered a partial of the purchase price to a representative of the vendor. During the Senate investigation, Arnault refused to reveal the identity of said representative, at the same time invoking his constitutional right against self-incrimination. The Senate adopted a resolution committing Arnault to the custody of the Sergeant-at-Arms (Leon Nazareno) and imprisoned in Bilibid “until he shall have purged the contempt by revealing to the Senate . . . the name of the person to whom he gave the P440,000, as well as answer other pertinent questions in connection therewith.” Arnault then filed a habeas corpus petition.
ISSUE 1: May the Senate impose penalty against those who refuse to answer its questions in a congressional hearing in aid of legislation?
HELD: Yes. It is the inherent right of the Senate to impose penalty in carrying out their duty to conduct inquiry in aid of legislation.
ISSUE 2: What is its limitation?
HELD: Must not violate an individual’s right against self-incrimination.
ISSUE 3: Supposed bills were already passed as a result of the inquiry, may the Senate still compel a witness to answer further inquiry?
HELD: Yes. Those bills have not yet been approved by the lower house and by the President and that they may be withdrawn or modified if after the inquiry is completed they should be found unnecessary or inadequate, there is nothing to prevent the Congress from approving other measures it may deem necessary after completing the investigation.
ISSUE 4: Supposed a witness thinks that the question propounded to him is not really in aid of legislation or is not material to the legislation sought, may the matter be resolved by the courts?
HELD: Yes. Where the alleged immateriality of the information sought by the legislative body from a witness is relied upon to contest its jurisdiction, the court is in duty bound to pass upon the contention. The fact that the legislative body has jurisdiction or the power to make the inquiry would not preclude judicial intervention to correct a clear abuse of discretion in the exercise of that power. HOWEVER, it is not necessary for the legislative body to show that every question propounded to a witness is material to any proposed or possible legislation; what is required is that is that it be pertinent to the matter under inquiry.
ISSUE 5: How long may a witness be detained?
HELD: A witness who refuses to answer a query by the Committee may be detained during the term of the members imposing said penalty but the detention should not be too long as to violate the witness’ right to due process of law.