Wikipedia lists this film as making $6 million in 1936:
They're not referring to the Benchley short subject, are they? Do you have any idea?
Funny you should ask just now. With the "Oscars" being awarded recently, there was an article in Smithsonian (http://blogs.smithsonianmag.com/movies/2012/02/what-ever-happened-to-the-short-film/ that addresses the issue, although not that specific film. Indeed, short subjects were big business in the golden age of Hollywood and did sometimes exceed the box office gross of the feature films. So the short answer is, yes, assuming the the Wikipedia entry is correct, then Robert Benchley's short, "How to be a Detective" was the highest grossing picture of 1936.