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Arnault vs.

Nazareno
G.R. No. L-3820
July 18, 1950
OZAETA, J.

Article 150. Disobedience to summons issued by the National Assembly, its committees or
subcommittees, by the Constitutional Commissions, its committees, subcommittees or divisions. - The
penalty of arresto mayor or a fine ranging from two hundred to one thousand pesos, or both such fine and
imprisonment shall be imposed upon any person who, having been duly summoned to attend as a
witness before the National Assembly, (Congress), its special or standing committees and
subcommittees, the Constitutional Commissions and its committees, subcommittees, or divisions, or
before any commission or committee chairman or member authorized to summon witnesses, refuses,
without legal excuse, to obey such summons, or being present before any such legislative or
constitutional body or official, refuses to be sworn or placed under affirmation or to answer any legal
inquiry or to produce any books, papers, documents, or records in his possession, when required by them
to do so in the exercise of their functions. The same penalty shall be imposed upon any person who shall
restrain another from attending as a witness, or who shall induce disobedience to a summon or refusal to
be sworn by any such body or official.

FACTS: The controversy arose from the purchase by the Philippine Government of two
estates: Buenavista Estate (for P4.5M) and Tambobong Estate for (for P500K). P1.5M
of the P5M sum paid by the government went to Ernest H. Burt, a nonresident
American, who had interests in both estates. The sum was paid to Burt through two
corporations both represented by Jean L. Arnault.

The Senate opened an investigation into the alleged overpayment by the government
for the two estates, including the government's paying to Burt the total sum of P1.5M for
his alleged interest of only P20,000 in the two estates, which he seemed to have
forfeited anyway long before. During the investigation by the Special Committe, Arnault
testified that he deposited the two checks aggregating P1.5M into an account and he
draw on said account two checks; one for P500K which he transferred to another
account and another for P440,000 which he encashed and gave to an unnamed
person.

For refusing to reveal the name of the person to whom he gave the P440,000 as well as
answer other questions, the Senate issued a Resolution holding Arnault in contempt
and ordering him to be imprisoned in the New Bilibid Prison until he gave the answers
requested. Hence, this petition for habeas corpus filed by Arnault.

ISSUE: Whether or not Arnault is guilty of violation of Article 150 of RPC

RULING: Yes. By refusing to answer the questions, the witness has obstructed the
performance by the Senate of its legislative function, and the Senate has the power to
remove the obstruction by compelling the witness to answer the questions thru restraint
of his liberty until he shall have answered them.
Arnault vs. Pecson
G.R. No. L-4027
September 2, 1950
TUAZON, J.

Article 152. Persons in authority and agents of persons in authority; Who shall be deemed as such. - In
applying the provisions of the preceding and other articles of this Code, any person directly vested with
jurisdiction, whether as an individual or as a member of some court or governmental corporation, board,
or commission, shall be deemed a person in authority. A barrio captain and a barangay chairman shall
also be deemed a person in authority.

A person who, by direct provision of law or by election or by appointment by competent authority, is


charged with the maintenance of public order and the protection and security of life and property, such as
a barrio councilman, barrio policeman and barangay leader and any person who comes to the aid of
persons in authority, shall be deemed an agent of a person in authority.

In applying the provisions of Articles 148 and 151 of this Code, teachers, professors and persons charged
with the supervision of public or duly recognized private schools, colleges and universities, and lawyers in
the actual performance of their professional duties or on the occasion of such performance, shall be
deemed persons in authority. (As amended by PD No. 299, Sept. 19, 1973 and Batas Pambansa Blg.
873, June 12, 1985).

FACTS: In the municipality of San Enrique, Negros Occidental, Hilarion


Sarcepuedes laid hands on Lucrecia L.Bustamante, a teacher-nurse, in the
school building of the town by hitting her twice on the face with his raincoat
and violently pushing her to the window. The assault took place because Lucrecia had
ordered the closing of a pathway across her land thru which Hilarion and his
wife to pass in going to and from the school, closing which Hilarion deeply
resented. It seems that Sarcepuedes sought Lucrecia Bustamante at the school
premises to demand an explanation. One word led to another and to the criminal
employment of force already described.

ISSUE: Whether or not the offended party is a person in authority

RULING: Yes. According to the Court of Appeals Lucrecia L. Bustamante was,


on the day of the commission of the offense, a teacher-nurse of the San Enrique
Elementary Public School, among her official duties being to give health instruction to
the pupils to instruct teachers about how to give first aid treatment in the school clinic
and to look after the sanitary facilities of the school. The contention must consequently
be overruled, since a teacher is expressly included in Article 152 among the officials
deemed to be persons in authority.