G.R. No. 235737 - Spouses Dorao vs. Spouses BBB and CCC

On January 13, 1947, Apolonio Cabansag filed a complaint for ejectment against Germiniana Fernandez et al. in the Court of First Instance of Pangasinan.
Defendants answered on January 31, 1947, moved to dismiss on February 2, 1947 (denied), and the court set multiple hearings between July 1947 and May 1952, but full trials were never completed due to repeated postponements and failure of stenographers to transcribe notes.

President Magsaysay issued Executive Order No. 1 (December 30, 1953), later superseded by EO No. 19 (March 17, 1954), creating the Presidential Complaints and Action Commission (PCAC) to expedite resolution of complaints against bureaucracy.
On August 12, 1954, frustrated by delays, Cabansag wrote to the PCAC (with copies to the Secretary of Justice and the Executive Judge), alleging deprivation of his land “thru the careful maneuvers of a tactical lawyer” and requesting PCAC intervention for prompt termination of his case.

The Secretary of Justice forwarded Cabansag’s letter to the CFI Pangasinan clerk, who referred it to Judge Morfe on August 27, 1954. Judge Morfe responded that stenographers were not obliged to transcribe outside appeals and were no longer under his jurisdiction.
On September 1, 1954, defense counsel Atty. Fernandez moved to hold Cabansag in contempt for scurrilous language; Cabansag’s counsel counter-moved against Fernandez. Judge Morfe dismissed both but ordered Cabansag (and on September 29, 1954, his lawyers Roberto V. Merrera and Rufino V. Merrera) to show cause why they should not be held for contempt for sending the letter.
After hearings with participation of the DOJ Special Counsel and local bar members as amici, the court found Cabansag and his two lawyers guilty of contempt, fining Cabansag ₱20 and each lawyer ₱50, warning of harsher penalties upon repeat.

Respondents timely appealed to this Court.
The trial court framed the issues as (a) whether the letter tended to degrade or embarrass the lower court, and (b) whether it invited PCAC intervention undermining the court’s independence.

Whether the letter sent by Cabansag to the PCAC tended directly or indirectly to place the lower court in disrepute, belittle or degrade it in its administration of justice.
Whether the letter tended to draw PCAC intervention in the pending ejectment case in a manner that would undermine the lower court’s judicial independence.