Title
Ang vs. Castro
Case
G.R. No. L-66371
Decision Date
May 15, 1985
Petitioner filed an administrative complaint against Judge Castro, leading to contempt charges and a libel case. Supreme Court ruled indirect contempt, privileged communication, and invalid libel charge, granting TROs and dismissing the case.
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Case Digest (G.R. No. L-66371)

Facts:

  1. Administrative Complaint Against Judge Castro:

    • In November 1983, petitioner Armando Ang filed an administrative complaint against respondent Judge Jose P. Castro for alleged ignorance of the law, gross negligence, incompetence, partiality, abuse of discretion, misconduct, and dereliction of duty in Civil Case No. Q-35466.
  2. Contempt Charge Against Petitioner:

    • On December 23, 1983, Judge Castro ordered petitioner to appear and show cause why he should not be punished for contempt of court for using disrespectful language in his administrative complaint.
    • On January 9, 1984, Judge Castro found petitioner guilty of contempt, sentenced him to five days imprisonment, and issued a warrant for his arrest after petitioner failed to appear at the hearing.
  3. Denial of Appeal:

    • Petitioner filed a notice of appeal on February 3, 1984, but Judge Castro denied it, stating that direct contempt judgments are not appealable.
  4. Libel Case Against Petitioner:

    • Judge Castro filed a criminal complaint for libel against petitioner based on the language used in the administrative complaint.
    • The libel case (Criminal Case No. Q-31587) was assigned to Judge Jose P. Arro of the Regional Trial Court, Branch CIII, Quezon City.
  5. Temporary Restraining Orders:

    • On February 20, 1984, the Supreme Court issued a temporary restraining order (TRO) to stop the enforcement of the arrest warrant and the preliminary investigation for libel.
    • On March 5, 1984, another TRO was issued to prevent Judge Arro from proceeding with the libel case.
  6. Failure to File Memoranda:

    • Both parties failed to submit their memoranda within the prescribed period, leading the Supreme Court to deem the case submitted for decision.

Issue:

  1. Whether petitioner’s failure to appear at the contempt hearing and his use of disrespectful language in his administrative complaint constituted direct contempt.
  2. Whether the denial of petitioner’s appeal from the contempt judgment was proper.
  3. Whether the libel case filed by Judge Castro against petitioner was valid, considering the privileged nature of the communication in the administrative complaint.

Ruling:

  1. On Contempt:

    • The Supreme Court ruled that petitioner’s conduct constituted indirect contempt, not direct contempt, as the disrespectful language was not uttered in the presence of or near the court to interrupt proceedings.
    • The Court held that petitioner’s appeal should have been allowed under Section 10, Rule 71 of the Rules of Court, which permits appeals in cases of indirect contempt.
  2. On Libel:

    • The Court ruled that the libel case was baseless because the communication in the administrative complaint was privileged.
    • The Court cited the doctrine in Santiago vs. Calvo, which holds that communications made in good faith in judicial or administrative proceedings are privileged and cannot be the basis for a libel charge.
  3. On Ancillary Actions:

    • The Court granted petitioner’s request to enjoin the enforcement of the arrest warrant and the libel case.
    • The TROs were made permanent, and Judge Castro was ordered to dismiss the libel case and forward the records of Civil Case No. Q-35466 to the Intermediate Appellate Court.

Ratio:

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