Case Digest: Arnault v. Balagtas 97 Phil 358

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

FACTS:  This was a petition for habeas corpus filed by Jean Arnault against the Director of Prisons, Balagtas. Arnault was incarcerated pursuant to a resolution by the Senate finding Arnault in contempt for refusing to disclose the name of a person with whom he transacted business in relation to a government purchase of of the Buenavista and Tambobong estates. The circumstances of Arnault's incarceration are described in the companion case Arnaultvs. Nazareno (1950) which affirmed the Legislature's power to hold a person in contempt for defying or refusing to comply with an order in a legislative inquiry. Arnault eventually divulged that he had transacted with one Jess D. Santos in relation to the Buenavista and Tambobong deal. Upon further inquiry, the Senate, obviously not satisfied with Arnault's explanations, adopted Resolution No. 114. 

DECISION:  Denied 

RATIO DECIDENDI:  The question raised by the petitioner was the legality of his detention by order of the Senate for his refusal to answer questions put to him by one of its investigating committees.   The Supreme Court refused to order his release and deferred to the discretionary authority of the legislative body to punish contumacious witnesses for contempt. The exercise of the legislature's authority to deal with the defiant and contumacious witness should be supreme and is not subject to judicial interference, except when there is a manifest and absolute disregard of discretion and a mere exertion of arbitrary power coming within the reach of constitutional limitations.