Case Digest: Arnault vs. Nazareno, GR L-3820, July 18, 1950

FACTS:  A petition for habeas corpus was filed by Arnault to relieve him from his confinement in the New Bilibid Prison to which he has been committed by virtue of a resolution adopted by the Senate on May 15, 1950. The Senate investigated the purchase by the government of two parcels of land, known as Buenavista and Tambobong estates. An intriguing question that the Senate sought to resolve was the apparent irregularity of the government’s payment to one Ernest Burt, a non-resident American citizen, of the total sum of Php1.5million for his alleged interest in the two estates that only amounted to Php20,000.00, which he seemed to have forfeited any way long before. The Senate sought to determine who were responsible for and who benefited from the transaction at the expense of the government. 

ISSUE:  Whether or not the senate has the authority to commit petitioner for contempt for a term beyond its period of legislative session 

DECISION:  Denied. 

RATIO DECIDENDI:  The Senate had the authority to commit petitioner for contempt for a term beyond its period of legislative session. There is no sound reason to limit the power of the legislative body to punish for contempt to the end of every session and not to the end of the last session terminating the existence of that body. The very reason for the exercise of the power to punish for contempt is to enable the legislative body to perform its constitutional function without impediment or obstruction.