Arnault v. Nazareno, G.R. No.
L-3820, July 18, 1950
Facts: This case arose from the legislative inquiry into the acquisition by the Philippine
Government of the Buenavista and Tambobong estates sometime in 1949. Among the witnesses
called to be examined by the special committee created by a Senate resolution was the herein
petitioner Jean L. Arnault, a lawyer who acted as agent of Ernest Burt in the subject transactions.
During the Senate investigation, Arnault refused to reveal the identity of said representative, at
the same time invoking his constitutional directly with the Supreme Court questioning the
validity of his right against self-incrimination. The Senate adopted a resolution committing
Arnault to the custody of the Sergeant-at-Arms and imprisoned. Arnault was therefore cited in
contempt by the Senate and was committed to the custody of the Senate Sergeant-at-Arms for
imprisonment until he answers the questions. He thereafter filed a petition for habeas
corpus detention.
Issue:
 Whether or not senate has the authority to commit petitioner for contempt for a term beyond its
period of legislative session?
RULING
       YES, the Senate had the authority to commit petitioner for contempt for a term beyond its
period of legislative session.
        The constitution provides that the Senate or the House of Representatives or any of its
respective committees may conduct inquiries in aid of legislation in accordance with its duly
published rules of procedure. The rights of persons appearing in or affected by such inquiries
shall be respected.
        In this case the court find 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. It must be herein established that the witness who refuses to answer a
query may be a query by the committee may be detained during the term of detention should not
be too long that will violate the right to due process.