G.R. No. 210430 - People vs. Nical y Alminario

The case originates from a dispute involving patent infringement and damages filed on August 16, 2013, by Colorsteel Systems Corporation and its president, Jose Rey S. Batomalaque, against Everglory Metal Trading Corporation.
The dispute arose after Everglory introduced the “Verona tile,” a product allegedly replicating patented designs owned by Batomalaque without his consent.
Colorsteel, having sent a cease-and-desist demand that went unheeded, escalated the matter by instituting a complaint for patent infringement with a request for a preliminary injunction.

The case was raffled to the sala of petitioner, Hon. Maria Amifaith S. Fider-Reyes, Presiding Judge of the Regional Trial Court (RTC) of San Fernando, Pampanga, Branch 42.
Everglory sought extensions to file its responsive pleading, citing complex factual and legal issues that required in-depth research and technical investigation.
On October 8, 2013, Everglory filed an Answer with a ground for outright dismissal of the complaint and a compulsory counterclaim, contending that the industrial designs in question lacked novelty or originality.

During the hearing for the preliminary injunction on October 25, 2013, petitioner, in open court, expunged from the records all prior pleadings and motions filed by Everglory and declared the hearing terminated, directing that the case be submitted for decision on the merits.
Everglory responded with a Motion for Reconsideration seeking to apply regular civil procedure; however, this motion was eventually denied in a resolution dated December 4, 2013.
On February 11, 2014, Everglory filed a Petition for Certiorari before the Court of Appeals (CA), challenging the RTC’s order and seeking a Temporary Restraining Order (TRO) and/or Preliminary Injunction, which culminated in the issuance of a 60-day TRO on April 22, 2014.

Prior to the expiration of the TRO on June 22, 2014, the CA rendered a decision on June 25, 2014 in a related certiorari proceeding, reversing and setting aside the RTC’s orders, and directing the case to be set for hearing for the presentation of petitioner’s evidence.
Despite this, petitioner resumed the summary proceedings in the infringement case, holding an order on November 19, 2014 which deemed certain pending incidents as submitted, followed by a judgment in the infringement case on December 3, 2014 in favor of Colorsteel and Batomalaque.
Colorsteel and Batomalaque sought relief via motions for reconsideration and a subsequent Petition for Review on Certiorari, all of which were ultimately denied, with the CA affirming certain orders and remanding the case for further proceedings in later resolutions.

On January 15, 2015, Everglory initiated a Petition for Indirect Contempt of Court against petitioner, alleging that she defied the CA’s decision (rendered on June 25, 2014) by proceeding with summary proceedings in the infringement case after the expiration of the TRO.
Petitioner defended her actions by asserting that:

She had faithfully executed her judicial duties.
There was no legal obstacle to continue with the proceedings, given that the CA decision had not attained finality.

On August 23, 2017, the CA found petitioner guilty of indirect contempt, characterizing her action as a willful defiance of the CA’s directive, and imposed a fine.
Petitioner’s subsequent Motion for Reconsideration was denied on April 12, 2018, prompting her to elevate the matter to the Supreme Court on the grounds that the CA had acted without proper jurisdiction in disciplining a lower court judge.

Whether the Court of Appeals has the inherent power to cite a lower court judge in indirect contempt of court.
Whether the imposition of a fine on a sitting lower court judge by the CA falls within its authority or instead encroaches on the exclusive disciplinary power of the Supreme Court.

Whether petitioner’s decision to proceed with the summary proceedings in the infringement case was legally justified given the pending certiorari and the non-finality of the CA decision.
Whether the continued proceedings, in defiance of the CA’s previous TRO and decision, constitute willful disobedience or merely an exercise of her judicial duty.