Facts:
Jean L. Arnault filed an original petition for habeas corpus to secure his release from confinement in the New Bilibid Prison, Muntinlupa, Rizal, following his commitment under a resolution of the
Philippine Senate dated May 15, 1950, which ordered that he be imprisoned until he "purged the contempt by revealing to the Senate or to the said special committee the name of the person to whom he gave the P440,000, as well as answer other pertinent questions in connection therewith." The commitment arose from an investigation by a Special Committee created by
Senate Resolution No. 8 (February 27, 1950) into the Government purchase in October 1949 of the Buenavista and Tambobong estates for aggregate payments of P5,000,000, involving payments totaling P1,500,000 to
Ernest H. Burt and the subsequent cashing by Arnault of a P440,000 check which he admitted he delivered to "a certain person" but repeatedly refused to name. Arnault had testified before the committee with inconsistent explanations — at times claiming inability to remember the name, at times invoking his constitutional right against
self-incrimination, and at times giving descriptive but unnamed identifications of the recipient — and after being brought before the bar of the Senate on May 15, 1950, and arraigned for contempt the Senate adopted the May 15 resolution committing him and authorized the Special Committee by
Senate Resolution No. 16 to continue its examination of him; Arnault then filed the present petition in this Court challenging the validity of his commitment.
Issues:
Did the Senate have power to punish
Jean L. Arnault for contempt for refusing to reveal the name of the person to whom he gave the P440,000 when asked by a duly authorized Senate committee? Was the Senate authorized to commit Arnault to custody for a term extending beyond the adjournment of the session in which the contempt occurred, given the character of the Senate as a continuing body? Was Arnault entitled to refuse to answer the question on the ground of
privilege against self-incrimination?
Ruling:
Ratio:
Doctrine: