Facts:

This case, G.R. No. 60007, involves a legal dispute between Noe C. Baja (the petitioner) and Honorable Judge Antonia Corpuz Macandog and Julian Munez (the respondents). The controversy arose from a civil case for specific performance and damages that Baja filed against Munez in the Regional Trial Court of Negros Occidental. Baja alleged that in their lease contract, Munez, as the lessee, was obligated to pay real estate taxes on the leased land. Baja later discovered that Munez had failed to pay over P4,000.00 in taxes and ignored Baja's demands for payment. Munez filed a "Manifestation" claiming he had paid the taxes, supporting his claim with a photocopy of the official receipt from the municipal treasurer of Escalante. The respondent Judge, upon this manifestation, dismissed Baja's complaint on July 24, 1981, stating it served to avoid docket congestion. Baja filed a Motion for Reconsideration and two other motions, including one seeking to declare Munez in

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Facts:

1. Contractual Dispute and Initial Complaint

   • Petitioner Noe C. Baja filed a civil case for specific performance and damages against private respondent Julian Munez in the Court of First Instance (now Regional Trial Court) of Negros Occidental.
   • The complaint alleged that Munez, as lessee, failed to pay real estate taxes on the leased land as stipulated in their lease contracts, despite Baja's demand.

2. Private Respondent's Manifestation

   • Munez filed a "Manifestation" stating he had already paid the realty taxes, supported by a xerox copy of an official receipt. He prayed for the dismissal of the complaint.
   • Respondent Judge Antonia Corpuz Macandog dismissed the case based on this "Manifestation" without a hearing, citing the need to avoid court congestion.

3. Petitioner's Motions and Contempt Proceedings

   • Baja filed a Motion for Reconsideration and an "Ex Parte Motion to Declare the Defendant in Default and to Disqualify the Presiding Judge."
   • Baja failed to appear at the scheduled hearing, leading the judge to hold him in contempt and order his arrest and imprisonment for six months.

4. Petitioner's Letter and Further Contempt Charges

   • While serving his sentence, Baja wrote a letter to the judge, accusing her of incompetence, bribery, and comparing her to "Bonnie and Clyde."
   • The judge found the letter slanderous and issued an order requiring Baja to explain why he should not be punished for indirect contempt.
   • Baja filed a "Manifestation" stating "there is nothing to explain," leading to his arrest and indefinite incarceration.

5. Supreme Court Intervention

   • The Supreme Court issued a temporary restraining order, halting the enforcement of the contempt orders and directing Baja's release.

Issue:

1. Whether the respondent judge committed grave abuse of discretion in dismissing Baja's complaint based solely on Munez's "Manifestation" without a hearing.
2. Whether the respondent judge erred in holding Baja in contempt and imposing excessive penalties for direct and indirect contempt.
3. Whether the petitioner's offensive language in his letter and motions warranted contempt charges.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Disposition

The Supreme Court granted certiorari, quashed the warrant of arrest, and declared the orders dated July 24, 1981, and February 12, 1982, null and void. The petitioner was reprimanded for his offensive language, and the temporary restraining order was made permanent.