Arnault vs.

Balagtas
G.R. No. L-6749
Jul 30, 1955
LABRADOR, J

Facts:
 The case involved Jean L. Arnault, who was an attorney in-fact of Ernest H. Burt in the negotiations for the
purchase of the Buenavista and Tambobong Estates by the Government of the Philippines.
 During an investigation conducted by the Senate Special Committee, Arnault was asked to whom a part of the
purchase price was delivered, but he refused to answer.
 As a result, the Committee ordered his confinement in the new Bilibid Prison until he revealed the information.
 Arnault challenged the legality of his confinement through a petition for habeas corpus.

Issue:
 Whether the Senate had the power to order the continued confinement of Arnault for refusing to disclose the
information.

Ruling:
 The Senate did have the power to punish recalcitrant witnesses as it was necessary to effectuate legislative power.
 The Senate's authority to deal with the defiant witness should be supreme, unless there is a manifest and absolute
disregard of discretion and a mere exertion of arbitrary power.
 The Senate had not believed Arnault's statement and his continued confinement was justified.
 Arnault's claim of purging himself of contempt was rejected.
 The length of Arnault's confinement did not exceed the maximum punishment for contempt under the law.

Ratio:
 The power to punish contempt falls exclusively within the legislative authority and is a necessary concomitant of
the legislative process.
 As long as the contempt is related to the exercise of legislative power and is committed in the course of the
legislative process, the legislature's authority to deal with the defiant witness should be supreme.
 The Senate had the power to confine Arnault for refusing to disclose information and his continued confinement
was justified.
 The separation of powers and the authority of the legislative branch to deal with contempt committed in the
course of the legislative process were emphasized.