Arnault vs Balagtas, 97 Phil 358 (1955)

ISSUE:  Whether or not Congress has authority to punish recalcitrant witness? 

FACTS:  Arnault continuously withheld information. This time about an affidavit supposedly giving details surrounding the acquisitions of the estates. To this he gave the name Jesse Santos as the person he gave the amount to. 

RATIO DECIDENDI:  Judgment appealed reversed. Provided the contempt is related to the exercise of the legislative power and is committed in the course of legislative process, the legislative authority is supreme. Said power must be considered implied or incidental to the exercise of legislative power or necessary to effectuate said power.