G.R. No. L-17507 - Ferrer vs. Rodriguez

Prior to 1949, the defendants (brothers and sisters) were in exclusive possession and control of 60 salt beds located in Dilain, Paranaque, Rizal.
On August 15, 1949, the Court of Appeals issued a decision declaring the plaintiffs as the owners of an undivided one-fourth, while the defendants were declared owners of the undivided three-fourths of the salt beds.
An agreement, approved by the court, was reached on March 15, 1952, between the parties regulating the procedures during the salt collection season:

Every morning, the salt collected would be measured by basket and then brought inside the bodega.
The bodega was to be secured with two padlocks with different keys—one held by the plaintiffs and the other by the defendants.
The agreement mandated that either the plaintiffs’ representative be present during operating hours or the camarin remain open until closing time in the afternoon.

The agreement was signed by Antonio Rodriguez (on behalf of the defendants), Trinidad Ferrer (on behalf of the plaintiffs), and by defendants Eusebia de Leon, Jose Lara, and Josefa Rodriguez, and was consistently followed from 1952 onward.

Forced open the door of the bodega by cutting and breaking the locking chain without notifying the plaintiffs or their representatives.
Proceeded to measure and remove several hundred sacks of salt from the premises.

The defendants were assisted by non-party individual Abelardo Marquez—described as the son of one of the defendants’ kasamas—and other persons (Andres San Agustin, Ernesto Marquez, Fausto Santos, Casiano Sarmiento, and Marcial Hernandez) in these acts of depredation.
Further, on December 24, 1956, with the assistance of an individual named Rogel and two policemen, the defendants again forced open the bodega by breaking the padlock chain owned by the plaintiffs, resulting in the removal of several hundred cavanes of salt.
Prior to these events, approximately 2,500 cavanes of salt were stored inside the bodega, and by the time the motion was filed, almost all of them had been taken by the defendants.

That all defendants and those aiding them (including the named individuals and policemen) be declared in contempt of court.
That an injunction be issued restraining the defendants and their workers from further acts of depredation and from disposing of the salt.

Defendants filed an answer on January 30, 1957, affirming that they had honored the 1952 agreement, and contended:

That procedural measures had been taken to ensure the presence of the plaintiffs’ representative during salt withdrawals.
That any absence of the plaintiffs’ representative (specifically Trinidad Ferrer) was due to her own actions, which included failing to appear when notified or neglecting invitations to witness the disposal of salt.
The defendants also explained their resort to the assistance of the local police to supervise certain transactions, maintaining that such actions were consistent with the agreement’s procedural requirements.

On September 30, 1959, the Court of First Instance dismissed the contempt complaint on the grounds that those accused, who were not actual parties to the civil case or signatories of the 1952 agreement, could not be held responsible for contempt or be bound by the provisions of the case.

There was a specific allegation of conspiracy between the acquitted defendants and the non-party respondents in violating the court’s order.
The involvement of non-parties, including a chief of police (Angel Sarmiento, who was also the husband of defendant Maria Rodriguez) and other policemen, suggested a coordinated effort.

However, the motion did not provide sufficient factual evidence to establish that the non-party respondents had knowledge of the order or that they willfully participated in its violation.
Citing precedents such as Narcida vs. Bowen, People vs. Rivera, and People ex rel. Stearns vs. Marr, the record emphasized that for a contempt charge, the act must be willful and executed with knowledge of the court’s order.

Whether individuals who are not parties to the civil proceeding (non-parties) may be declared in contempt for violating a court order issued in that proceeding.
Whether the procedures for serving and notifying non-parties are relevant in imposing contempt sanctions under the Rules of Court.

Whether the alleged conspiracy between the defendants and non-party respondents provided a sufficient basis to extend liability for contempt to those who were not direct parties to the agreement or the civil case.

Whether the elements of willful disobedience and knowledge of the court’s order were adequately established in the factual record, particularly concerning the involvement of non-parties in the alleged acts of depredation.