### Facts:
This case revolves around the events following the death of Horacio Tomas T. Castillo III, a University of Santo Tomas (UST) law student, allegedly due to hazing conducted by the Aegis Juris Fraternity. The Senate launched an investigation, leading to Arvin Balag’s (petitioner) contempt citation and detention by the Senate Committee on Public Order and Dangerous Drugs.
– **September 17, 2017**: Horacio III dies, purportedly due to fraternity hazing.
– **September 19-20, 2017**: Senate Resolutions 504 and 510 are filed condemning the hazing death and setting an inquiry.
– **September 25, 2017**: Senate inquiry begins; Balag fails to attend this session.
– **October 9, 2017**: Spouses Castillo file a Supplemental Complaint-Affidavit, citing the Senate hearing’s transcripts.
– **October 11 & 17, 2017**: Balag receives subpoenas for the October 18 hearing.
– **October 18, 2017**: During the hearing, Balag invokes his right against self-incrimination when questioned about his fraternity presidency. He is later cited in contempt and detained.
The case followed through various legal procedures, including the filing of this petition arguing the inquiry was in aid of prosecution, not legislation, and questioning the Senate’s contempt power application.
### Issues:
1. Whether the Senate Committees’ conduct of the legislative inquiry and citing the petitioner in contempt constituted grave abuse of discretion.
2. The legality and duration of detaining a person cited in contempt during legislative inquiries.
### Court’s Decision:
The Supreme Court ruled the petition moot and academic since Balag was already released, and the legislative inquiry had concluded. However, the Court decided to address the concern regarding the duration of detention under the Senate’s contempt power. The Court established that the duration of imprisonment for contempt during inquiries should last only until the termination of the legislative inquiry.
### Doctrine:
The Supreme Court clarified the limits of detention under the Senate’s contempt power, stating it should only extend until the end of the legislative inquiry, either through the approval/disapproval of the Committee Report or at the expiration of one Congress.
### Class Notes:
– **Legislative Inquiries**: Governed by Article VI, Section 21 of the Constitution, allowing Congress to conduct inquiries in aid of legislation, respecting the rights of persons appearing therein.
– **Contempt Power**: The inherent power to ensure compliance with its processes, including detention of recalcitrant witnesses, but must be exercised within bounds, particularly regarding the duration of detention.
– **Key Legislations & Articles**:
– Senate Rules of Procedure Governing Inquiries in Aid of Legislation
– Republic Act No. 8049 (Anti-Hazing Law)
– Article VI, Section 21 of the Philippine Constitution
### Historical Background:
The case highlights the tension between legislative powers to conduct inquiries in aid of legislation and individual rights, particularly against self-incrimination and unlawful detention. It underscores the Senate’s role in investigating matters of public interest, while also setting limits on its contempt power to protect individuals’ rights. This balancing act reflects the judiciary’s role in maintaining checks and balances in the Philippine government system.
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