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G.R. No.

L-3820 July 18, 1950 HELD:

o The petition must be denied, with costs.
JEAN L. ARNAULT, petitioner
LEON NAZAREON, respondents o In the present case the jurisdiction of the Senate, thru the Special Committee, to investigate the
Buenavista and Tambobong Estates deal is not challenged by the petitioner. The Court entertains no
FACTS: doubt as to the Senate’s authority to do so and as to the validity of Resolution No. 8. The transaction
o This is an original petition for habeas corpus to relieve the petitioner from his confinement in the New involved a questionable and allegedly unnecessary and irregular expenditure of no less than P5, 000, 000
Bilibid Prison to which he has been committed by virtue of a resolution adopted by the Senate. of public funds.
o In the latter part of October 1949, the Philippine Government, through the Rural Progress Administration, o The inquiry, to be within the jurisdiction of the legislative body to make, must be material or necessary to
bought two estates known as Buenavista and Tambobong for the sums of P4, 500,000 and P500, 000 the exercise of a power in it vested by the Constitution, such as to legislate, or expel a Member; and every
respectively. P1,000,000 for the first sum and P500, 000 to the second sum was paid to Ernest H. Burt, a question which the investigator is empowered to coerce a witness to answer must be material or pertinent
non-resident American, thru his attorney-in-fact in the Philippines, as represented by Jean Arnault, for both to the subject of the inquiry or investigation. In other words, the materiality of the question must be
estates, respectively. However, Ernest H. Burt was not the original owner of the estate. He bought the first determined by its direct relation to any proposed or possible legislation.
from San Juan de Dios hospital and the second from the Philippine Trust Company. In both instances, o The Court finds that the question for the refusal to answer which the petitioner was held in contempt by the
Burt was not able to pay the necessary amount of money to complete his payments. As such, his contract Senate is pertinent to the matter under inquiry. In fact, this is not and cannot be disputed. Senate
with said owners was cancelled. Resolution No. 8, the validity of which is not challenged by the petitioner, requires the Special Committee,
o On September 4, 1947, the Philippine Trust Company sold, conveyed, and delivered the Tambobong to determine the parties responsible for the Buenavista and Tambobong estates deal, and it is obvious
Estate to the Rural Progress Administration by an absolute deed of sale. The Philippine Government then that the name of the person to whom the witness gave the P440, 000 involved in said deal is pertinent to
accomplished the purchase of the two estates in the latter part of October 1949. that determination – it is in fact the very thing sought tobe determined.
o On February 27, 1950, the Senate adopted its Resolution No. 8, which created a special committee to o The very reason for the exercise of the power to punish for contempt is to enable the legislative body to
investigate the transactions surrounding the estates. The committee sought to determine who were perform its constitutional function without impediment or obstruction. By refusing to answer the questions,
responsible for and who benefited from the transaction at the expense of the Government. the witness has obstructed the performance of the Senate of its legislative function.
o Arnault testified that two checks payable to Burt aggregating P1, 500, 000 were delivered to him; that on o The petitioner’s insistent claim before the bar of the Senate that if he should reveal the name he would
that same date, he opened a new account in the name of Ernest Burt with the Philippine National Bank in incriminate himself, necessarily implied that he knew the name. moreover, it is unbelievable that he gave
which he deposited the two checks. Petitioner drew on said account for the two checks and encashed the the P440, 000 to a person to him unkown. Generally, the question whether testimony is privileged is for
P440, 000 payable to cash. the determination of the Court. Al least, it is not enough for the witness to say that the answer will
o It was the desire of the committee to determine the ultimate recipient of this sum of P440, 000 that gave incriminate him, as he is not the sole judge of his liability. The danger of elf- incrimination must appear
rise to the present case. Petitioner resisted to name the recipient of the money. Hence, this present reasonable and real to the court, from all circumstances, and from the whole case, as well as from his
petition. general conception of ther elations of the witness. The petitioner cannot assert his privilege by reason of
some fanciful excuse, for the protection against an imaginary danger, or to secure immunity to a third
ISSUE: person.
o Whether or not Senate has the power to punish petitioner for contempt for the refusal to reveal the name
of the person to whom he gave the P440, 000.
o Whether or not the privilege against self-incrimination protects petitioner from being questioned.
G.R. No. L- 6749 July 30, 1955

JEAN L. ARNAULT, petitioner-appellee

EUSTAQUIO BALAGTAS, respondent-appellant

o This is an appeal from the judgement of the Court of First Instance in habeas corpus proceeding, declaring
that the continued detention and confinement of Jean Arnault in the New Bilibid Prison, in pursuance of
Senate Resolution No. 114, is illegal for the reason that the Senate committed a clear abused of discretion
in considering his answer naming one Jess D. Santos as to the person whom delivery of the sum of P440,
000 was made in the sale of the Buenavista and Tambobong estate, as a refusal to answer the question
directed by the Senate committee to him, and on the ground that said petitioner, by his answer, has
purged himself of contempt and is consequentially entitled to be released and discharged.
o While still in confinement in Bilibid, petitioner-appellee executed an affidavit wherein he gives detail the
history of his life, the events surrounding the acquisition of Buenavista and Tambobong Estates by Gen.
Burt, the supposed circumstances under which he met one by the name of Jess D. Santos. Upon the
presentation of the said affidavit to said Senate Special Committee, the latter subjected petitioner to
questioning regarding identity of Jess D. Santos, and after said questioning the Committee adopted
Resolution No. 114 which reads: “Resolution approving the report of the Special Committee to investigate
Buenavista and Tambobong Estates Deal, and ordering the Director of Prison to continue holding Jean
Arnault in his custody, and in confinement and detention at the New Bilibid Prison until said Arnault shall
have purged himself of contempt of the Senate.
o Whether or not the continued confinement and detention of the petitioner-appellee, as ordered in Senate
Resolution No. 114, is valid.