Thursday, March 25, 2021

DIGEST/NORIZA JEAN DAGA/LORENZO SHIPPING CORPORATION, OCEANIC CONTAINER LINES, INC., SOLID SHIPPING LINES CORPORATION, SULPICIO LINES, INC., ET AL.vs. DMAP, LORENZO CINCO, and CORA CURAY

 LORENZO SHIPPING CORPORATION, OCEANIC CONTAINER LINES, INC., SOLID SHIPPING LINES CORPORATION, SULPICIO LINES, INC., ET AL., Petitioners,

vs.

DISTRIBUTION MANAGEMENT ASSOCIATION OF THE PHILIPPINES, LORENZO CINCO, and CORA CURAY, Respondents. 

G.R. No. 155849               August 31, 2011

 

Facts:

     The Maritime Industry Authority (MARINA) issued a Letter-Resolution, advising respondent Distribution Management Association of the Philippines (DMAP) that a computation of the required freight rate adjustment by MARINA was no longer required for freight rates officially considered or declared deregulated in accordance with MARINA Memorandum Circular No. 153 (MC 153).   In order to challenge the constitutionality of EO 213, MC 153, and the Letter-Resolution dated June 4, 2001, DMAP commenced in the Court of Appeals (CA) a special civil action for certiorari and prohibition, with prayer for preliminary mandatory injunction or temporary restraining order.

            DMAP appealed to the Court, but Court denied DMAP’s petition for review on certiorari "for petitioners’ failure to: (a) take the appeal within the reglementary period of fifteen (15) days in accordance with Section 2, Rule 45 in relation to Section 5(a), Rule 56, in view of the foregoing denial of petitioners' motion for extension of time to file the petition; and (b) pay the deposit for sheriff's fee and clerk's commission in the total amount of ₱202.00 in accordance with Sections 2 and 3, Rule 45 in relation to Section [c], Rule 56 and paragraph 1 of Revised Circular No. 1-88 of this Court."

            In October 2002, DMAP held a general membership meeting (GMM) on the occasion of which DMAP, acting through its co-respondents Lorenzo Cinco, its President, and Cora Curay, a consultant/adviser to Cinco, publicly circulated the Sea Transport Update.        

    The petitioners filed this petition to charge the respondents with indirect contempt of court for including allegedly contemptuous statements in their so-called Sea Transport Update concerning the Court’s resolutions issued on June 5, 2002 and August 12, 2002. They alleged that the publication unfairly debased the Supreme Court by making “scurrilous, malicious, tasteless, and baseless innuendo” to the effect that the Supreme Court had allowed itself to be influenced by the petitioners as to lead the respondents to conclude that the “Supreme Court ruling issued in one month only, normal lead time is at least 3 to 6 months.” They averred that the respondents’ purpose, taken in the context of the entire publication, was to “defy the decision, for it was based on technicalities, and the Supreme Court was influenced!” 

In their comment, the respondents denied any intention to malign, discredit, or criticize the Court. They explained that their statement that the “Supreme Court ruling issued in one month time only, normal lead time is at least three to six months” was not per se contemptuous, because the normal and appropriate time frame for the resolution of petitions by the Court was either less than a month, if the petition was to be denied on technicality, and more or less from three to six months, if the petition was to be given due course; that what made the petitioners describe the statement as contemptuous was not the real or actual intention of the author but rather the petitioners’ false, malicious, scurrilous and tasteless insinuations and interpretation; and that the petitioners, not being themselves present during the GMM, had no basis to assert that the that the DMAP’s presentor, the author of the material, or any of the speakers during the GMM had any evil intention or made any malicious insinuations.

 

Issue:

            Whether the statements contained in the Sea Transport Update constitute or amount to indirect contempt of court?

 

Ruling:

            Contempt of court has been defined as a willful disregard or disobedience of a public authority. In its broad sense, contempt is a disregard of, or disobedience to, the rules or orders of a legislative or judicial body or an interruption of its proceedings by disorderly behavior or insolent language in its presence or so near thereto as to disturb its proceedings or to impair the respect due to such a body. In its restricted and more usual sense, contempt comprehends a despising of the authority, justice, or dignity of a court. The phrase contempt of court is generic, embracing within its legal signification a variety of different acts.

            Contempt of court is of two kinds, namely: direct contempt, which is committed in the presence of or so near the judge as to obstruct him in the administration of justice; and constructive or indirect contempt, which consists of willful disobedience of the lawful process or order of the court.

The punishment for the first is generally summary and immediate, and no process or evidence is necessary because the act is committed in facie curiae. The inherent power of courts to punish contempt of court committed in the presence of the courts without further proof of facts and without aid of a trial is not open to question, considering that this power is essential to preserve their authority and to prevent the administration of justice from falling into disrepute; such summary conviction and punishment accord with due process of law. There is authority for the view, however, that an act, to constitute direct contempt punishable by summary proceeding, need not be committed in the immediate presence of the court, if it tends to obstruct justice or to interfere with the actions of the court in the courtroom itself. Also, contemptuous acts committed out of the presence of the court, if admitted by the contemnor in open court, may be punished summarily as a direct contempt, although it is advisable to proceed by requiring the person charged to appear and show cause why he should not be punished when the judge is without personal knowledge of the misbehavior and is informed of it only by a confession of the contemnor or by testimony under oath of other persons.

Indirect contempt is defined by and punished under Section 3, Rule 71 of the Rules of Court, which provides:

Section 3. Indirect contempt to be punished after charge and hearing. — After a charge in writing has been filed, and an opportunity given to the respondent to comment thereon within such period as may be fixed by the court and to be heard by himself or counsel, a person guilty of any of the following acts may be punished for indirect contempt:

(a) Misbehavior of an officer of a court in the performance of his official duties or in his official transactions;

(b) Disobedience of or resistance to a lawful writ, process, order, or judgment of a court, including the act of a person who, after being dispossessed or ejected from any real property by the judgment or process of any court of competent jurisdiction, enters or attempts or induces another to enter into or upon such real property, for the purpose of executing acts of ownership or possession, or in any manner disturbs the possession given to the person adjudged to be entitled thereto;

(c) Any abuse of or any unlawful interference with the processes or proceedings of a court not constituting direct contempt under section 1 of this Rule;

(d) Any improper conduct tending, directly or indirectly, to impede, obstruct, or degrade the administration of justice;

(e) Assuming to be an attorney or an officer of a court, and acting as such without authority;

(f) Failure to obey a subpoena duly served;

(g) The rescue, or attempted rescue, of a person or property in the custody of an officer by virtue of an order or process of a court held by him.

Misbehavior means something more than adverse comment or disrespect. There is no question that in contempt the intent goes to the gravamen of the offense. Thus, the good faith, or lack of it, of the alleged contemnor should be considered. Where the act complained of is ambiguous or does not clearly show on its face that it is contempt, and is one which, if the party is acting in good faith, is within his rights, the presence or absence of a contumacious intent is, in some instances, held to be determinative of its character. A person should not be condemned for contempt where he contends for what he believes to be right and in good faith institutes proceedings for the purpose, however erroneous may be his conclusion as to his rights. To constitute contempt, the act must be done willfully and for an illegitimate or improper purpose.

The petitioners did not sufficiently show how the respondents’ publication of the Sea Transport Update constituted any of the acts punishable as indirect contempt of court under Section 3 of Rule 71.

The petitioners’ mere allegation, that "said publication unfairly debases the Supreme Court because of the scurrilous, malicious, tasteless, and baseless innuendo therein that the Court allowed itself to be influenced by the petitioners as concocted in the evil minds of the respondents thus leading said respondents to unjustly conclude: Supreme Court ruling issued in one month only, normal lead time is at least 3 to 6 months," was insufficient, without more, to sustain the charge of indirect contempt.

 The test for criticizing a judge’s decision is, therefore, whether or not the criticism is bona fide or done in good faith, and does not spill over the walls of decency and propriety. Viewed through the prism of the test, the Sea Transport Update was not disrespectful, abusive, or slanderous, and did not spill over the walls of decency and propriety. Thereby, the respondents were not guilty of indirect contempt of court.

No comments:

Post a Comment