G.R. No. L-6749 July 30, 1955
Labrador, J.:
Topic:
Legislative power
Facts:
1.
The controversy arose out of the Government's
purchase of 2 estates, the Buenavista and Tambobong Estates. Petitioner
was the attorney in-fact of Ernest H. Burt in the negotiations for the purchase
which was effected. The price paid for both estates was P5, 000,000.
2.
Thereafter, the Senate adopted Resolution No. 8
creating a Special Committee to determine the validity of the purchase and
whether the price paid was fair and just. During the said Senate investigation,
petitioner was asked to whom a part of the purchase price, or P440, 000, was
delivered. Petitioner refused to answer this question, hence the Committee
cited him in contempt for contumacious acts and ordered his commitment to the
custody of the Sergeant at-arms of the Philippines Senate and imprisoned in the
new Bilibid Prison he reveals to the Senate or to the Special Committee the
name of the person who received the P440, 000 and to answer questions pertinent
thereto. Petitioner filed a habeas corpus proceeding.
3.
CFI ruled that the continued
detention and confinement of petitioner pursuant to a Senate Resolution No.
114, is illegal, and that the Senate committed a clear abuse of discretion in
not considering his answer naming one Jess D. Santos as the person to whom
delivery of the sum of P440,000 was made. Further, on the ground that that
petitioner, by his answer has purged himself of contempt and is consequently
entitled to be released and discharged.
ISSUE:
W/N the Senate has the power to punish the petitioner for contempt
YES
1.
The Congress or any of its bodies has the power to punish recalcitrant
witnesses. This is implied or incidental or necessary to the exercise of
legislative power. The 1987 Constitution adopted the principle of
separation of powers, making each branch supreme within the realm of its
respective authority; it must have intended each department's authority to be
full and complete, independent of the other's authority and power.
2.
Provided that contempt is related to the exercise of the legislative
power and is committed in the course of the legislative process, the
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.
3.
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 wherein offenders are
brought to the courts of justice for punishment that 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.
ISSUE 2: W/N petitioner has already purged himself
of contempt
4.
No. It is true that he gave a name, Jess D. Santos, as the person to
whom delivery of the sum of P440, 000 was made. However, the Senate Committee
refused to believe that this is the real name of the person whose identity is
being the subject of the inquiry. The Senate, therefore, held that the act of
the petitioner continued the original contempt, or reiterated it.
5.
Finally, it is improper for the courts to declare that the
continued confinement is an abuse of the legislative power and thereby
interfere in the exercise of the legislative discretion.
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