Case Digest (G.R. No. L-3820) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jean L. Arnault v. Leon Nazareno, Sergeant-at-Arms, Philippine Senate, and Eustaquio Balagtas, Director of Prisons (87 Phil. 29, G.R. No. L-3820, July 18, 1950), petitioner Jean L. Arnault, who had acted as representative for Ernest H. Burt in the sale of the Buenavista Estate (P4,500,000) and Tambobong Estate (P500,000) to the Rural Progress Administration, was summoned by a Senate Special Committee created under Senate Resolution No. 8 (February 27, 1950). The Committee was investigating alleged irregularities and excessive costs in those transactions. On October 29, 1949, Arnault received P1,500,000 in checks on behalf of Burt, deposited them in Burt’s bank account, and then cashed a P440,000 check which he handed to an unnamed “representative of Burt.” Despite repeated questioning in public hearings conducted by the Committee, Arnault refused to disclose the recipient’s name, first claiming a right of privacy and later invoking his privilege against self-incrimination. On Case Digest (G.R. No. L-3820) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition for Habeas Corpus
- Jean L. Arnault was committed to New Bilibid Prison under Senate Resolution of May 15, 1950, for refusing to reveal the identity of the person to whom he delivered P440,000.
- The resolution directed imprisonment “until discharged by further order of the Senate or by the special committee” upon “purging the contempt” by answering.
- Buenavista and Tambobong Estates Deal
- In October 1949, the government (through the Rural Progress Administration and Philippine National Bank) bought two estates for P5,000,000 in the aggregate.
- Of the P1,500,000 paid to Ernest H. Burt, attorney-in-fact Jean L. Arnault received two checks, deposited them, then cashed P440,000 and delivered it to “a representative of Burt” whose name he refused to divulge.
- Senate Investigation and Contempt Proceedings
- Senate Resolution No. 8 (Feb. 27, 1950) created a special committee to investigate the transaction, with power to subpoena and compel testimony.
- Arnault testified before the committee, claimed privilege against self-incrimination and privacy, but later admitted he knowingly delivered P440,000 to an unnamed person.
- On May 15, 1950, the Senate held him in contempt for refusing to name the recipient and ordered his commitment pending compliance.
- Arnault filed an original petition for habeas corpus before the Supreme Court.
Issues:
- Contempt Power of the Senate
- Whether the Senate has authority to punish a non-member for contempt in refusing to answer questions pertinent to a valid legislative inquiry.
- Duration of Contempt Commitment
- Whether the Senate may enforce a contempt commitment beyond the adjournment of the session in which it was imposed.
- Privilege Against Self-Incrimination
- Whether Arnault validly invoked the constitutional privilege to refuse naming the recipient to avoid self-incrimination.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)