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ARNAULT vs NAZARENO GR 3820 July 18, 1950 Ponente: Ozaeta, J.

FACTS:

Philippine Government bought two estates (Buenavista and Tambobong) for the sum of Php4.5M and Php500k paid to Ernest Burt, an American nonresident, through his attorneys-in-fact represented in both sales by Arnault. The original owners of both estates sold them to Burt on the condition of him paying in installment until the expiration dates. But the expiration dates passed without Burt completing his payments on either sale. The Court of First Instance of Rizal then ordered to cancel his certificate of title and issuance on the estates. Feb, 27 1950, Senate adopted Resolution creating a special committee to investigate the case. The committee examined various witnesses, the most important of them being Arnault. Government found an irregularity that it paid an unnecessary amount to Burt. Arnault testified that the interests of Burt were deposited aggregating Php1.5M. He then said that he drew two checks one of Php500k, which he transferred to Associate Agencies account, and another of Php440k which he cashed himself. The committee tried to determine who was the recipient of the Php440k, which was the unnecessary amount of charge. The committee interpellated Arnault on who was the recipient of the amount he cashed for several sessions. Arnault stated in the beginning through a letter to the Senate President that: o I beg to be excused from making answers which might later be used against me. I have been assured that it is my constitutional right to refuse to incriminate myself and I am certain that the Honorable Members of this committee will see the justness of my position. He claimed at the beginning that he did not know the name of the recipient of the amount. This later changed into him not remembering what the name was. The committee ordered that he be arraigned for contempt of contumacious acts during the investigation. He was placed in custody of the Sergeant-at-Arms imprisoned until he could reveal to Senate the name of the person he gave the money to. Arnault field petition for habeas corpus to relieve his confinement in the New Bilibid Prison

ISSUES: - Did the committee have the right to compel the witness to answer their questions during the interpellation? - Was the committee within jurisdiction to compel the witness through placing him under custody of the Sergeant-at-Arms? HELD/ RATIONALE: - Yes. The court held the committee did have a right because the questions were pertinent to the matter of inquiry. If the subject is within range of legitimate inquiry and the proposed testimony of the witness called relates to that subject, obedience to its process may be enforced by the committee by imprisonment. - Yes. The court held that if the basis of the power of the legislature to punish for the contempt exists while the legislative body exercising it is in session, then that power and the exercise thereof must perforce continue until its final adjournment and the election of its successor. RELEVANT LAWS: - No person can be punished for contumacy as a witness before either House of Congress unless his testimony is required in a matter into which that house has jurisdiction to inquire.