Arnault Vs Balagtas

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Arnault vs Balagtas Issues: 1.

Did the Senate Special Committee believe the statement of the petitionerappellee that the person to whom he gave the P440,000 is one by the name of Jess D. Santos and if it did not, may the court review said finding? And 2. If the Senate did not believe the statement, is the continued confinement and detention of the petitioner-appellee, as ordered in Senate Resolution of November 8, 1952, valid? Held: The judgment appealed from should be, as it hereby is, reversed, and the petition for the issuance of the writ of habeas corpus denied. The order of the court allowing the petitioner to give bail is declared null and void and the petitioner is hereby ordered to be recommitted to the custody of the respondent. 1. NO. It is clear and evident that the Senate Committee did not believe petitioner's statement that the person to whom he delivered the abovementioned amount is one by the name of Jess D. Santos. accdg to senate lower court believes the opinion or conclusion of the Senate Committee is not borne to out by the evidence produced at the investigation, that the Senate abused its discretion in making its conclusion and that under these circumstances the only thing that could in justice be done to petitioner is to order his release and have his case endorsed to the prosecution branch of the judicial department for investigation and prosecution as the circumstances warrant. LOWER COURT IS WRONG o It assumed that courts have the right to review the findings of legislative bodies in the exercise of the prerogative of legislation, or interfere with their proceedings or their discretion in what is known as the legislative process o THIS COURT (the judicial department of the government) has no right or power or authority to do, much in the same manner that the legislative department may not invade the judicial realm in the ascertainment of truth and in the application and interpretation of the law, in what is known as the judicial process, because that would be in direct conflict with the fundamental principle of separation of powers established by the Constitution. The only instances when judicial intervention may lawfully be invoke are when there has been a violation of a constitutional inhibition, or when there has been an arbitrary exercise of the legislative discretion. o All that the courts may do, in relation to the proceedings taken against petitioner prior to his incarceration, is to determine if the constitutional guarantee of due process has been accorded him before his incarceration by legislative order, and this because of the mandate of the Supreme Law of the land that no man shall be deprived life, liberty or property without due process of law Arnault was given due process 2. valid

Senate found that the petitioner-appellee did not disclose, by the mere giving of the name Jess D. Santos, the identity of the person to whom the sum of P440, 000 was delivered, and, in addition thereto that petitioner withheld said identity arrogantly and contumaciously in continued affront of the Senate's authority and dignity. The resolution refuses to relate CONFINEMENT as PUNISHMENT o Merely seeks to get the identity of the person o Kinda intention is to punish accused for being arrogant in not disclosing the truth Senate has the authority to commit a witness if he refuses to answer a question pertinent to a legislative inquiry, to compel him to give the information, i.e., by reason of its coercive power, not its punitive power. o Petitioner contends that if he is to be punished for not disclosing the identity, he needs to go through the judicial process The principle that Congress or any of its bodies has the power to punish recalcitrant witnesses is founded upon reason and policy. Said power must be considered implied or incidental to the exercise of legislative power, or necessary to effectuate said power. o The process by which a contumacious witness is dealt with by the legislature in order to enable it to exercise its legislative power or authority must be distinguished from the judicial process by which offenders are brought to the courts of justice for the meting of the punishment which the criminal law imposes upon them. The former falls exclusively within the legislative authority, the latter within the domain of the courts; because the former is a necessary concomitant of the legislative power or process, while the latter has to do with the enforcement and application of the criminal law. o legislature's authority to deal with the defiant and contumacious witness should be supreme, and unless there is a manifest and absolute disregard of discretion and a mere exertion of arbitrary power coming within the reach of constitutional limitations, the exercise of the authority is not subject to judicial interference. The next question concerns the claim that the petitioner has purged himself of contempt, because he says he has already answered the original question which he had previously been required to answer o In order that the petitioner may be considered as having purged himself of the contempt, it is necessary that he should have testified truthfully, disclosing the real identity of the person subject of the inquiry. o No person guilty of contempt may purge himself by another lie or falsehood; this would be repetition of the offense. o Senate did not believe that Jess D Santos is the real person o The Senate, therefore, held that the act of the petitioner continued the original contempt, or reiterated it 1 last contention of petitioner remains to be considered. It is the claim that as the period of imprisonment has lasted for a period which exceeded that provided by law punishment for contempt, i. e., 6 months of arresto mayor, the petitioner is now entitled to be released. o This claim is not justified by the record. Petitioner was originally confined by Resolution No. 17 on May 15, 1950. On December 13, 1951, he executed his affidavit and thereafter he was called to testify again before the Senate Committee. The latter passed its Resolution No. 114 on November 6, 1952, and he presented the petition for habeas corpus in this case on March 3, 1953, i. e., five months after the last resolution when the Senate found that the petitioner committed another contempt.

It is not true, therefore, that the petitioner's punishment is beyond the full period prescribed in the criminal law.

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