ARNAULT VS NAZARENO

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 Jean L. Arnault, a lawyer who delivered a
partial of the purchase price to a representative of the vendor. During the Senate investigation, Arnault
refused to reveal the identity of said representative, at the same time invoking his constitutional right
against self-incrimination. The Senate adopted a resolution committing Arnault to the custody of the
Sergeant-at-Arms and imprisoned “until he shall have purged the contempt by revealing to the Senate . .
. the name of the person to whom he gave the P440,000, as well as answer other pertinent questions in
connection therewith.” Arnault petitioned for a writ of Habeas Corpus.
ISSUE:
Can the senate impose penalty against those who refuse to answer its questions in a congressional
hearing in aid of legislation.
HELD:
It is the inherent right of the Senate to impose penalty in carrying out their duty to conduct inquiry
in aid of legislation. But it must be herein established that a witness who refuses to answer a query by the
Committee may be detained during the term of the members imposing said penalty but the detention
should not be too long as to violate the witness’ right to due process of law.
There is no provision in the Constitution expressly investing either House of Congress with power
to make investigations and exact testimony to the end that it may exercise its legislative functions as to
be implied. In other words, the power of inquiry — with process to enforce it — is an essential and
appropriate auxiliary to the legislative function. A legislative body cannot legislate wisely or effectively in
the absence of information respecting the conditions which the legislation is intended to effect or change;
and where the legislative body does not itself possess the requisite information — which is not
infrequently true — recourse must be had to others who do possess it. Experience has shown that mere
requests for such information are often unavailing, and also that information which is volunteered is not
always accurate or complete; so some means of compulsion is essential to obtain what is needed.
(McGrain vs. Daugherty, 273 U.S., 135; 71 L. ed., 580; 50 A.L R., 1.) The fact that the Constitution expressly
gives to Congress the power to punish its Members for disorderly behavior, does not by necessary
implication exclude the power to punish for contempt any other person. (Anderson vs. Dunn, 6, Wheaton,
204; 5 L. ed., 242.) But no person can be punished for contumacy as a witness before either House, unless
his testimony is required in a matter into which that House has jurisdiction to inquire.
The inquiry, to be within the jurisdiction of the legislative body to make, must be material or
necessary to the exercise of a power in it vested by the Constitution, such as to legislate, or to expel a
Member; and every question which the investigator is empowered to coerce a witness to answer must be
material or pertinent to the subject of the inquiry or investigation.
BENGZON VS SENATE BLUE RIBBON COMMITTEE

FACTS:

It was alleged that Benjamin “Kokoy” Romualdez and his wife together with the Marcoses
unlawfully and unjustly enriched themselves at the expense of the Filipino people. That they obtained
with the help of the Bengzon Law Office and Ricardo Lopa – Cory’s brother in law, among others, control
over some of the biggest business enterprises in the country including MERALCO, PCI Bank, Shell
Philippines and Benguet Consolidated Mining Corporation.
Senator Juan Ponce Enrile subsequently delivered a privilege speech alleging that Lopa took over
various government owned corporations which is in violation of the Anti-Graft and Corrupt Practices Act.
Contained in the speech is a motion to investigate on the matter. The motion was referred to the
Committee on Accountability of Public Officers or the Blue Ribbon Committee. After committee hearing,
Lopa refused to testify before the committee for it may unduly prejudice a pending civil case against him.
Bengzon likewise refused invoking his right to due process. Lopa however sent a letter to Enrile
categorically denying his allegations and that his allegations are baseless and malicious.
Enrile subsequently took advantage of the Senate’s privilege hour upon which he insisted to have
an inquiry regarding the matter. The SBRC rejected Lopa’s and Bengzon’s plea.
Claiming that the Senate Blue Ribbon Committee is poised to subpoena them and require their
attendance and testimony in proceedings before the Committee, in excess of its jurisdiction and legislative
purpose, in clear and blatant disregard of their constitutional rights, and to their grave and irreparable
damage, prejudice and injury, and that there is no appeal nor any other plain, speedy and adequate
remedy in the ordinary course of law, Bengzon et al filed a petition for prohibition with a prayer for
temporary restraining order and/or injunctive relief against the SBRC.
ISSUE:
Whether or not the inquiry sought by the SBRC be granted.
HELD:
No, the inquiry cannot be given due course. The speech of Enrile contained no suggestion of
contemplated legislation; he merely called upon the Senate to look into a possible violation of Sec. 5 of
RA No. 3019, otherwise known as “The Anti-Graft and Corrupt Practices Act.” In other words, the purpose
of the inquiry to be conducted by the Blue Ribbon Committee was to find out whether or not the relatives
of Cory, particularly Lopa, had violated the law in connection with the alleged sale of the 36 or 39
corporations belonging to Kokoy to the Lopa Group. There appears to be, therefore, no intended
legislation involved. Hence, the contemplated inquiry by the SBRC is not really “in aid of legislation”
because it is not related to a purpose within the jurisdiction of Congress, since the aim of the investigation
is to find out whether or not the relatives of the President or Mr. Ricardo Lopa had violated Section 5 of
RA No. 3019, the “Anti-Graft and Corrupt Practices Act”, a matter that appears more within the province
of the courts rather than of the legislature. Besides, the Court may take judicial notice that Mr. Ricardo
Lopa died during the pendency of this case.
BOLINAO ELECTRONIC CORPORATION VS VALENCIA

FACTS:

Bolinao Electronics Corporation was the co-owner and a co-petitioner of Chronicle Broadcasting Network,
Inc. (CBN) and Montserrat Broadcasting System Inc. They operate and own television (channel 9) and radio
stations in the Philippines. They were summoned by Brigido Valencia, then Secretary of Communications,
for operating even after their permit has expired. Valencia claimed that because of CBN’s continued
operation sans license and their continuing operation had caused damages to his department.
ISSUE:
Whether or not Valencia is entitled to claim for damages.
HELD:
The SC ruled in the negative. Valencia failed to show that any right of his has been violated by the
refusal of CBN to cease operation. Further, the SC noted that as the records show, the appropriation to
operate the Philippine Broadcasting Service as approved by Congress and incorporated in the 1962-1963
Budget of the Republic of the Philippines does not allow appropriations for TV stations particularly in
Luzon. Hence, since there was no appropriation allotted then there can be no damage; and if there are
expenditures made by Valencia’s department they are in fact in violation of the law and they cannot claim
damages therefrom. And even if it is shown that the then president vetoed this provision of the Budget
Act, such veto is illegal because he may not legally veto a condition attached to an appropriation or item
in the appropriation bill.
Under the Constitution, the President has the power to veto any particular item or items of an
appropriation bill. However, when a provision of an appropriation bill affects one or more items of the
same, the President cannot veto the provision without at the same time vetoing the particular item or
items to which it relates. (Art. VI, Sec. 20.)
It may be observed from the wordings of the Appropriations Act that the amount appropriated
for the operation of the Philippine Broadcasting Service was made subject to the condition that the same
shall not be used or expended for operation of television stations in Luzon, where there are already
existing commercial television stations. This gives rise to the question of whether the President may legally
veto a condition attached to an appropriation or item in the appropriation bill. But this is not a novel
question. A little effort to research on the subject would have yielded enough authority to guide action
on the matter For, in the leading case of State v. Holder,2 it was already declared that such action by the
Chief Executive was illegal. This ruling, that the executive’s veto power does not carry with it the power
to strike out conditions or restrictions, has been adhered to in subsequent cases.3 If the veto is
unconstitutional, it follows that the same produced no effect whatsoever,4 and the restriction imposed
by the appropriation bill, therefore, remains. Any expenditure made by the intervenor PBS, for the
purpose of installing or operating a television station in Manila, where there are already television stations
in operation, would be in violation of the express condition for the release of the appropriation and,
consequently, null and void. It is not difficult to see that even if it were able to prove its right to operate
on Channel 9, said intervenor would not have been entitled to reimbursement of its illegal expenditures.
BARA LIDASAN VS COMMISSION ON ELECTIONS

FACTS:

Bara Lidasan was a resident of Parang, Cotabato. Later, Republic Act No. 4790, entitled “An Act Creating
the Municipality of Dianaton in the Province of Lanao del Sur,” was passed. Lidasan however discovered
that certain barrios located in Cotabato were included in Dianaton, Lanao Del Sur pursuant to RA
4790. [Remarkably, even the Congressman of Cotabato voted in favor of RA 4790.] Pursuant to this law,
COMELEC proceeded to establish precincts for voter registration in the said territories of Dianaton.
Lidasan then filed a case to have RA 4790 be nullified for being unconstitutional. He averred that the
law did not clearly indicate in its title that in creating Dianaton, it would be including in its territory
several barrios from Cotabato.
ISSUE:
Whether or not RA 4790 is constitutional
HELD:
No. The said law is void. The baneful effect of the defective title here presented is not so difficult to
perceive. Such title did not inform the members of Congress as to the full impact of the law; it did not
apprise the people in the towns of Buldon and Parang in Cotabato and in the province of Cotabato itself
that part of their territory is being taken away from their towns and province and added to the adjacent
Province of Lanao del Sur; it kept the public in the dark as to what towns and provinces were actually
affected by the bill that even a Congressman from Cotabato voted for it only to find out later on that it is
to the prejudice of his own province. These are the pressures which heavily weigh against the
constitutionality of RA 4790.
TOBIAS VS ABALOS

FACTS:

Residents of Mandaluyong, herein petitioners assail the constitutionality of Republic Act No.
7675, otherwise known as "An Act Converting the Municipality of Mandaluyong into a Highly Urbanized
City to be known as the City of Mandaluyong."

A plebescite was held wherein the people of Mandaluyong were asked whether they approved of
the conversion of the Municipality of Mandaluyong into a highly urbanized city as provided under R.A. No.
7675. The turnout at the plebiscite was only 14.41% of the voting population. Nevertheless, 18,621 voted
"yes" whereas 7,911 voted "no." By virtue of these results, R.A. No. 7675 was deemed ratified and in
effect.

Petitioner claims that it is violative of the “one subject one bill” rule ennunciated in Section 26 of
article VI of the Constitution. Petitioners allege that the the law embraces 2 subjects: (1) the conversion
of Mandaluyong into a highly urbanized city; and (2) the division of the congressional district of San
Juan/Mandaluyong into two separate districts. They also argue that the division of San Juan and
Mandaluyon would result to an increase in the composition of the house of representatives

ISSUE:

Whether or not the law is valid

RULING:

The law is valid. Contrary to petitioners' assertion, the creation of a separate congressional
district for Mandaluyong is not a subject separate and distinct from the subject of its conversion into a
highly urbanized city but is a natural and logical consequence of its conversion into a highly urbanized city.
Verily, the title of R.A. No. 7675, "An Act Converting the Municipality of Mandaluyong Into a Highly
Urbanized City of Mandaluyong" necessarily includes and contemplates the subject treated under Section
49 regarding the creation of a separate congressional district for Mandaluyong.

Moreover, a liberal construction of the "one title-one subject" rule has been invariably adopted
by this court so as not to cripple or impede legislation. Thus, in Sumulong v. Comelec (73 Phil. 288 [1941]),
we ruled that the constitutional requirement as now expressed in Article VI, Section 26(1) "should be
given a practical rather than a technical construction. It should be sufficient compliance with such
requirement if the title expresses the general subject and all the provisions are germane to that general
subject."

As to the contention that the assailed law violates the present limit on the number of
representatives as set forth in the Constitution, a reading of the applicable provision, Article VI, Section
5(1), as aforequoted, shows that the present limit of 250 members is not absolute.