Thursday, March 25, 2021

DIGEST/SUZEYNE KIM GARCIA/PROSECUTOR JORGE D. BACULI v. JUDGE MEDEL ARNALDO B. BELEN

 

PROSECUTOR JORGE D. BACULI v. JUDGE MEDEL ARNALDO B. BELEN

A.M. No. RTJ-09-2176               April 20, 2009

 

FACTS:

In a Decision dated 18 December 2006, respondent Judge Belen found complainant Baculi guilty of direct contempt of court for making scurrilous and contumacious statements in the latter’s Urgent Reiterative Motion. Complainant Baculi was again cited for indirect contempt of court, in another Decision dated 7 June 2007 and sentenced to pay a fine of Twenty Thousand Pesos (₱20,000.00) and to suffer imprisonment of three (3) days.

Complainant Baculi filed a Notice of Appeal with Motion and Manifestation dated 5 July 2007 praying that the execution of the decision finding him guilty of indirect contempt be suspended pending his appeal. Respondent Judge Belen, in an Order dated 6 August 2007, directed complainant Baculi to post, within two (2) days from receipt thereof, a supersedeas bond of Thirty Five Thousand Pesos (₱35,000.00) in order to stay the execution of the Decisions dated 18 December 2006 and 7 June 2007.

Complainant Baculi moved for a reduction of the bond but the same was treated as a mere scrap of paper for failure to comply with the notice of hearing under Rule 15 of the Rules of Court.

Respondent Judge Belen, in an Order dated 20 August 2007, directed the clerk of court to issue the Writ of Execution and a Warrant of Arrest to implement the decision of 18 December 2006 and 7 June 207. Said order also directed the Philippine National Police to assist the branch sheriff in the enforcement of the Warrant.

Complainant moved to set aside the Order dated 20 August 2007. In his twin Orders of 24 March 2008, respondent Judge Belen declared that the Decisions dated 18 December 2006 and 7 June 2007 are final and executory. On 28 April 2008, complainant Baculi filed a Motion for Reconsideration and to Set Aside Decisions of December 18, 2006 and June 7, 2007 and all Orders of March 24, 2008.

Thereafter, complainant filed the instant Complaint, asseverating, among others, that respondent violated Section 7, Rule 71 of the Rules of Court and prevailing jurisprudence in holding him liable for indirect contempt because the use of contemptuous language in a pleading, if submitted before the same judge, would constitute only direct contempt of court; that complainant's conviction had no basis because the pleadings in question did not contain any vulgar, vile or unethical statements that would be an affront to the dignity of the court; that the supersedeas bond of ₱35,000.00 fixed by the court to stay the execution was excessive, confiscatory and unconscionable; and that respondent was induced by revenge and ill motive, since it was complainant who indicted respondent in a libel case filed by one Prosecutor Ma. Victoria Sunega-Lagman, docketed as Criminal Case No. 15332-SP, now pending before the RTC, Branch 32, San Pablo City. Thus, complainant charges respondent with abuse of the court’s power to cite persons for contempt.

 

ISSUE:

WON the Order citing Complainant of indirect contempt is proper.

 

RULING:

No, the Court finds the respondent guilty of gross ignorance of the law for citing complainant for indirect contempt.

 

In Re: Conviction of Judge Adoracion G. Angeles, RTC, Br. 121, Caloocan City in Crim. Cases Q-97-69655 to 56 for Child Abuse, the Court held:

 

Contempt of court is a defiance of the authority, justice or dignity of the court, such conduct as tends to bring the authority and administration of the law into disrespect or to interfere with or prejudice parties, litigant or their witnesses during litigation.

 

There are two kinds of contempt punishable by law: direct contempt and indirect contempt. Direct contempt is committed when a person is guilty of misbehavior in the presence of or so near a court as to obstruct or interrupt the proceedings before the same, including disrespect toward the court, offensive personalities toward others, or refusal to be sworn or to answer as a witness, or to subscribe an affidavit or deposition when lawfully required to do so. Indirect contempt or constructive contempt is that which is committed out of the presence of the court. Any improper conduct tending, directly or indirectly, to impede, obstruct, or degrade the administration of justice would constitute indirect contempt.

 

A pleading containing derogatory, offensive or malicious statements submitted before a court or judge where the proceedings are pending constitutes direct contempt, because it is equivalent to misbehavior committed in the presence of or so near a court or judge as to interrupt the administration of justice. In this regard, respondent committed a serious blunder when he cited complainant for indirect contempt.

 

Respondent also failed to follow the proper procedure under Section 4 of Rule 71 of the Revised Rules of Civil Procedure, which particularly provides:

 

SEC. 4. How proceedings commenced. — Proceedings for indirect contempt may be initiated motu proprio by the court against which the contempt was committed by an order or any other formal charge requiring the respondent to show cause why he should not be punished for contempt.

 

In all other cases, charges for indirect contempt shall be commenced by a verified petition with supporting particulars and certified true copies of documents or papers involved therein, and upon full compliance with the requirements for filing initiatory pleadings for civil actions in the court concerned. If the contempt charges arose out of or are related to a principal action pending in the court, the petition for contempt shall allege that fact but said petition shall be docketed, heard and decided separately, unless the court in its discretion orders the consolidation of the contempt charge and the principal action for joint hearing and decision.

 

As correctly observed by the OCA, there was no order issued by respondent for the charge of indirect contempt against complainant to be docketed separately; neither was there an order that the said charge be consolidated with the principal action. In sum, respondent simply incorporated or integrated the proceedings for indirect contempt with the principal case. This fortifies the OCA’s finding that respondent is grossly ignorant of basic procedure. When the law is so elementary, such as the provisions of the Rules of Court, not to know, or to act as if one does not know the same, constitutes gross ignorance of the law.

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