Case Digest (G.R. No. 139844)
Facts:
- Atty. Salome D. CaAas filed a petition against Hon. Lerio C. Castigador and Prosecutor Onofre M. Maranan regarding a temporary restraining order and writ of preliminary injunction.
- The case arose from a vehicular accident on May 1, 1996, involving a Mitsubishi Lancer and an Isuzu truck.
- A criminal complaint was filed against Nestor V. Guevarra for reckless imprudence on May 20, 1996.
- Atty. CaAas, representing the truck owner, filed a motion for the release of the vehicle, promising to produce Guevarra for bail on May 23, 1996.
- She arrived late on May 23 due to traffic and left a note for the judge.
- A warrant for Guevarra's arrest was issued on July 17, 1996, and the judge recalled the release order on August 14, 1996, but Atty. CaAas did not receive the order due to an incorrect address.
- Prosecutor Maranan filed a motion for contempt against Atty. CaAas on September 26, 1996, without providing her a copy.
- Atty. CaAas did not attend the hearing on October 8, 1996, due to the same address issue.
- On December 5, 1996, Atty. CaAas was found guilty of indirect contempt and fined P100 with a 30-day imprisonment.
- The Court of Appeals upheld the contempt order, prompting Atty. CaAas to file a petition for review.
Issue:
- (Unlock)
Ruling:
- The Supreme Court reversed the Court of Appeals' decision and the contempt order against Atty. CaAas.
- The motion to dec...(Unlock)
Ratio:
- The Supreme Court determined that the judge acted improperly in citing Atty. CaAas for indirect contempt.
- The Court emphasized that contempt powers should be exercised with restraint and not out of vindictiveness.
- The judge's actions indicated personal hostility rather than a commitment to uphold court dignity.
- Contempt proceedings are criminal and require strict adherence to procedural rules, includin...continue reading
Case Digest (G.R. No. 139844)
Facts:
The case involves Atty. Salome D. CaAas as the petitioner against Hon. Lerio C. Castigador, the Municipal Trial Court Judge of General Trias, Cavite, and Prosecutor Onofre M. Maranan, among others, in relation to a petition for a temporary restraining order and writ of preliminary injunction. The events leading to the case began on May 1, 1996, when a vehicular accident occurred along Governor's Drive, Barangay San Francisco, General Trias, Cavite. The accident involved a Mitsubishi Lancer driven by Amado Praxedes and an Isuzu truck owned by Isagani R. Medina, driven by Nestor V. Guevarra. Following the incident, a criminal complaint was filed on May 20, 1996, against Guevarra for reckless imprudence resulting in serious physical injuries and damage to property, which was docketed as Criminal Case No. 3890.
On May 21, 1996, Atty. CaAas, representing Medina, filed a motion for the release of the Isuzu trailer truck. She assured the court that she would produce the accused, Guevarra, on May 23, 1996, to post bail. However, on May 23, she arrived late due to heavy traffic and found that the judge was no longer present. She left a note informing the judge of her appearance. Subsequently, on July 17, 1996, a warrant for Guevarra's arrest was issued, and on August 14, 1996, the judge recalled the order for the release of the trailer, requiring Atty. CaAas to surrender it to the court. However, the order was not received by her due to an incorrect address on the envelope.
On September 11, 1996, the judge reiterated the order to surrender the trailer, which again went unreceived by Atty. CaAas. On September 26, 1996, Prosec...