1. The Supreme Court ruled that the Senate committee's detention of the petitioner for contempt was moot since the legislative inquiry had ended with the committee's approval of its report.
2. The Court held that the Senate's power of contempt during legislative inquiries is limited to the duration of the inquiry, at which point detention must cease.
3. The Court affirmed that indefinite detention would violate constitutional rights, and set the precedent that detention under legislative contempt powers can only last until the termination of the relevant inquiry.
1. The Supreme Court ruled that the Senate committee's detention of the petitioner for contempt was moot since the legislative inquiry had ended with the committee's approval of its report.
2. The Court held that the Senate's power of contempt during legislative inquiries is limited to the duration of the inquiry, at which point detention must cease.
3. The Court affirmed that indefinite detention would violate constitutional rights, and set the precedent that detention under legislative contempt powers can only last until the termination of the relevant inquiry.
1. The Supreme Court ruled that the Senate committee's detention of the petitioner for contempt was moot since the legislative inquiry had ended with the committee's approval of its report.
2. The Court held that the Senate's power of contempt during legislative inquiries is limited to the duration of the inquiry, at which point detention must cease.
3. The Court affirmed that indefinite detention would violate constitutional rights, and set the precedent that detention under legislative contempt powers can only last until the termination of the relevant inquiry.
1. The Supreme Court ruled that the Senate committee's detention of the petitioner for contempt was moot since the legislative inquiry had ended with the committee's approval of its report.
2. The Court held that the Senate's power of contempt during legislative inquiries is limited to the duration of the inquiry, at which point detention must cease.
3. The Court affirmed that indefinite detention would violate constitutional rights, and set the precedent that detention under legislative contempt powers can only last until the termination of the relevant inquiry.
- Petitioner attended the hearing but refused to answer the question TOPIC Power to Punish a Person Under Investigation from Senator Poe “if he was the president of the AJ Fraternity.” He CASE NO. G.R. No. 234608 invoked his right against self-incrimination. - This question was repeated twice before given a warning from CASE NAME Balag v. Senate Senator Lacson that he could be cited in contempt. Nonetheless he PONENTE Gesmundo, J still refused to answer. Senator Poe moved to cite him in contempt PETITIONER Balag seconded by Senator Villanueva and Zubiri. Senator Lacson RESPONDENT Senate Committee on Public Order and Dangerous reminded him that this was just an affirmation of school records. Drugs, Senate Committee on Justice and Human (Detention of someone in contempt happens after the committee Rights, Senate Committee on Constitutional hearing hence why he was still being asked questions) Amendments and Revisions and Balajadia as Senate - After around 40 minutes. Lacson and Poe gave him another chance Sergant at Arms repeating the said question 2 more times but refused to answer. TYPE OF Petition for Certiorari and Prohibition with a prayer - After 1 hour and 10 minutes. Villanueva asked him if he was the one CASE for a TRO and/or writ of preliminary injunction who decided to bring him to Chinese general hospital. This was MEMBER Raymond Conchu where he admitted to being a member of AJ Frat but not aware who the president was since he was enrolled in another school. ISSUE - Villanueva repeated his question that was being evaded again but petitioner gave the same response. Villanueva said his contempt 1. W/N Senate committee acted with grave abuse of discretion in would then remain. conducting the legislative inquiry citing petitioner in contempt. Petitioners Arguments 2. W/N there is a limitation to the period of detention when the Senate - The Legislative inquiry was not in aid of Legislation exercises its power of contempt during inquiries in aid of legislation o Since the transcripts during the investigation were being used during the criminal complaint against him in aid of RELEVANT FACTS prosecution. - Horacio Tomas T. Castillo III law student of UST, died allegedly o It would violate his right to due process and pre-empt due to hazing conducted by the Aegis Juris Fraternity finding of the DOJ - Senator Zubiri directed the appropriate Senate Committee to - Equal Protection laws were violated investigate, in aid of legislation, to hold those responsible - He properly invoked his right to Self- incrimination accountable. - Petitioner, however, did not attend the hearing scheduled. - Senator Lacson issued a Subpoena Ad Testificandum to the petitioner directing him to testify on the subject matter.
1 CONSTITUTION I A.Y. 1819– DEAN CANDELARIA - Accordingly, as long as there is a legitimate legislative inquiry, then RATIO DECIDENDI the inherent power of contempt by the Senate may be properly 1. W/N Senate committee acted with grave abuse of discretion in exercised. Conversely, once the said legislative inquiry concludes, conducting the legislative inquiry citing petitioner in contempt. the exercise of the inherent power of contempt ceases and there is no MOOT AND ACADEMIC more genuine necessity to penalize the detained witness.
- Court finds that there is no more justiciable controversy. As - When does Legislative Inquiry End? discussed earlier, in its resolution dated December 12, 2017, the o Committee Reports approval or disapproval signifies the end of Court ordered in the interim the immediate release of petitioner such legislative inquiry and it is now up to the Senate whether pending resolution of the instant petition. Thus, petitioner was no or not to act upon the said Committee Report in the succeeding longer detained under the Senate's authority. order of business. - ▪ Committee report is the culmination of the legislative - Evidently, respondent committees have terminated their legislative inquiry inquiry. The Senate even went further by approving on its 3rd ▪ Senate Rules Section 22 and 23 reading the proposed bill, Senate Bill No. 1662, the result of the ● Within fifteen (15) days after the conclusion of the inquiry in aid of legislation. As the legislative inquiry ends, the basis inquiry, the Committee shall meet to begin the for the detention of petitioner likewise ends. consideration of its Report. o Upon the expiration of that Congress at the final adjournment of 2. W/N there is a limitation to the period of detention when the its last session. Senate exercises its power of contempt during inquiries in aid of ▪ Optional for the Senate of the succeeding congress to take legislation up such unfinished matters, not in the same status, but as if - Moreover, the indefinite detention of persons cited in contempt presented for the first time. impairs their constitutional right to liberty. Thus, paramount public ▪ Even though Senate is a continuing institution all interest requires the Court to determine such issue to ensure that the proceedings are terminated upon its expiration. constitutional rights of the persons appearing before a legislative inquiry of the Senate are protected. DISPOSITIVE POSITION - Constitutional right to liberty that every citizen enjoys certainly WHEREFORE, the petition is DENIED for being moot and academic. cannot be respected when they are detained for an indefinite period However, the period of imprisonment under the inherent power of contempt of time without due process of law. of the Senate during inquiries in aid of legislation should only last until the - The Court finds that the period of imprisonment under the inherent termination of the legislative inquiry. The December 12, 2017 Resolution of power of contempt by the Senate during inquiries in aid of the Court ordering the temporary release of Arvin R. Balag from detention is legislation should only last until the termination of the legislative hereby declared FINAL inquiry under which the said power is invoked
2 CONSTITUTION I A.Y. 1819– DEAN CANDELARIA DOCTRINE/PRECEDENT - (Anderson v. Dunn) although the offense committed under the inherent power of contempt by Congress may be undefinable, it is justly contended that the punishment need not be indefinite. It held that as the legislative body ceases to exist from the moment of its adjournment or periodical dissolution, then it follows that imprisonment under the contempt power of Congress must terminate with adjournment. - (Neri v. Senate) Senate as a "continuing body" there is no debate that the Senate as an institution is "continuing'', as it is not dissolved as an entity with each national election or change in the composition of its members. However, in the conduct of its day-to-day business the Senate of each Congress acts separately and independently of the Senate of the Congress before it.
RELEVANT LAWS Rules of Senate RULEXLIV UNFINISHED BUSINESS
SEC. 123. Unfinished business at the end of the session shall be taken up at the next session in the same status. All pending matters and proceedings shall terminate upon the expiration of one (l) Congress, but may be taken by the succeeding Congress as if present for the first time. Undeniably from the foregoing, all pending matters and proceedings, i.e., unpassed bills and even legislative investigations, of the Senate of a particular Congress are considered terminated upon the expiration of that Congress and it is merely optional on the Senate of the succeeding Congress to take up such unfinished matters, not in the same status, but as if presented for the first time.
