Cited Laws
Accordingly, the House Committee may validly issue the Contempt and Detention Order, provided that the requisite quorum and votes under Section 11 of the House Rules for Legislative Inquiries were met. The Speaker of the House need not sign the Contempt and Detention Order because it is not required by Section 11. Relevantly, the Contempt and Detention Order expressly states that "upon unanimous vote of the Members of the Committee present, there being a quorum, [Mayor Dolor) [has] been cited for CONTEMPT and ordered DETAINED at the House of Representatives until the termination of the inquiry." [79] It thus appears that the requisite quorum and votes under Section 11 were complied with when the House Committee issued the Contempt and Detention Order. There is therefore no reason for the Court to declare the Contempt and Detention Order null and void for failure to comply with the House Rules for Legislative Inquiries. 3. The House Committee may validly conduct hearings while the House is in adjournment Next, petitioner avers that the Contempt and Detention Order is void because the House had already adjourned its Third Regular Session on February 5, 2025, which resumed only on June 2, 2025. She implies that the House Committee cannot validly hold a hearing on March 17, 2025, and cause the arrest of Mayor Dolor on March 27, 2025, while the House was in adjournment. Supposedly, with such adjournment, the citation of Mayor Dolor for contempt and his detention cannot be in aid of legislation. Petitioner's arguments are contrary to the relevant rules and jurisprudence. The Court has long recognized that legislative functions may be and in practice are performed by the duly constituted committees of the House or the Senate that are charged with the duty of performing investigations, hearings, or inquiries relative to any proposed legislation. [80] In fact, Article VI, Section 21 [81] of the 1987 Constitution expressly states that legislative inquiries may be conducted by the committees of the Senate or the House. Likewise, Rule IX, Section 26 [82] of the Rules of the House of the 19th Congress directs the House to organize committees that shall act upon matters that were referred to them by the House, including the conduct of inquiries in aid of legislation. [83] Relatedly, the Court held in Arnault v. Nazareno [84] that the Senate and the House may authorize their duly constituted committees to conduct legislative inquiries and investigations even during congressional recess . Balag v. Senate of the Philippines [85] similarly instructs that the Senate, while on recess , may exercise its power of contempt during legislative hearings. In this regard, Rule IX, Section 35 of the Rules of the House of the 19th Congress provides that a House committee may conduct meetings, conferences, or hearings at such time that it may determine. When the House has adjourned or is in recess, the House Committee on Rules and such committees to which it has granted permis