LOPEZ VS.

DE LOS REYES

G.R. NO. 34361, NOV 5, 1930, MALCOLM, J

Art. 144. Disturbance of proceedings. — The penalty of arresto mayor or a fine from 200
to 1,000 pesos shall be imposed upon any person who disturbs the meetings of the
National Assembly (Congress of the Philippines) or of any of its committees or
subcommittees, constitutional commissions or committees or divisions thereof, or of any
provincial board or city or municipal council or board, or in the presence of any such
bodies should behave in such manner as to interrupt its proceedings or to impair the
respect due it. (Reinstated by E.O. No. 187).

Facts:

Candido B. Lopez filed a petition for the writ of habeas corpus seeking relief from his
restraint of liberty. He was arrested by a ranking officer of the Constabulary under a
warrant of arrest issued by the Speaker of the House of Representatives. The arrest
was based on resolutions of the House finding Lopez guilty of contempt for assaulting
Representative Jose D. Dimayuga while on his way to attend the sessions of the House.
The House adopted a resolution for Lopez's arrest and confinement in Bilibid Prison for
twenty-four hours, but the order of arrest was not served on Lopez before the session
adjourned. During the third session of the Philippine Legislature, a confirmatory
resolution was approved, and a new warrant of arrest was issued.

Issue:

Whether the House of Representatives has the power to punish for contempt, and if so,
whether the punishment can extend beyond the session in which the contempt
occurred.

Ruling:
The House of Representatives has the power to punish for contempt, which arises by
implication and is justified by the right of self-preservation. However, this power is
limited to imprisonment for a term not exceeding the session in which the contempt
occurred. The punishment imposed during the third session of the Philippine Legislature
was beyond the authority of the House of Representatives. Therefore, the court granted
the writ of habeas corpus and ordered the discharge of Lopez from custody.