Facts:
Respondent
Everglory Metal Trading Corporation filed an infringement case,
IPR Civil Case No. 005, against Colorsteel Systems Corporation (
Colorsteel) and its president, Jose Rey S. Batomalaque, on August 16, 2013, which was raffled to the sala of petitioner, Hon. Maria Amifaith S. Fider-Reyes, then Presiding Judge of the Regional Trial Court (RTC), City of San Fernando, Pampanga, Branch 42. Batomalaque was the registered owner of three patents for specific designs of a tile roofing panel, and Everglory manufactured and marketed the “Verona tile,” alleged to be an exact copy of the patented products without notice and consent, prompting Colorsteel to send a demand letter to cease and desist and then to file for infringement with application for preliminary injunction. In the infringement case, Everglory filed two motions for extension to file its responsive pleading, and on October 8, 2013 it filed an
Answer with Ground for the Outright Dismissal and with
Compulsory Counterclaim. During the scheduled hearing for the preliminary injunction on October 25, 2013, petitioner rendered in open court a verbal order expunging all motions and previous pleadings filed by Everglory and terminating the hearing on the preliminary injunction application, then submitting the principal case for decision. Everglory moved for reconsideration and asked that the regular civil procedure be applied; the RTC denied the motion in a resolution dated December 4, 2013, leading Everglory to file a petition for
certiorari with prayer for
TRO and/or preliminary injunction before the Court of Appeals (CA), docketed as
CA-G.R. SP No. 133942, assailing the RTC orders. On April 22, 2014, the CA issued a
60-day TRO enjoining petitioner from further proceedings pending resolution of the certiorari case, but the TRO expired on June 22, 2014. On June 25, 2014, the CA rendered a decision granting Everglory’s petition, finding grave abuse of discretion in the RTC resolutions, reversing and setting aside the RTC orders, and directing the RTC to set the case for hearing to allow petitioner to present its evidence and to decide with dispatch under the Rules of Court. Colorsteel and Batomalaque sought reconsideration, which was denied on November 20, 2014, and they later filed a petition for review on certiorari before this Court (
G.R. No. 215921), which was denied on March 16, 2015, after which the resolution became final and entry of judgment was directed on September 2, 2015. Meanwhile, petitioner issued an order on November 19, 2014 stating that, with the expiration of the TRO and the absence of any further restraining order, the pending incidents and the main case would be deemed submitted, and on December 3, 2014 she rendered a decision on the merits of the infringement case in favor of Colorsteel and Batomalaque. Everglory then filed multiple proceedings, including a petition for review under Rule 43 (
CA-G.R. SP No. 138582) and a certiorari petition challenging RTC denials of a motion for voluntary inhibition (
CA-G.R. SP No. 138410). In a consolidated ruling dated September 10, 2015, the CA granted Everglory’s petitions, declared the RTC resolutions null and void, and remanded
IPR Case No. 005 to the RTC for re-raffle to another branch and for further proceedings. Colorsteel and Batomalaque’s motion for reconsideration was denied on February 2, 2016. Thereafter, Everglory filed a petition for
indirect contempt against petitioner before the CA on January 15, 2015, alleging that petitioner defied the CA decision dated June 25, 2014 by continuing summary proceedings after the TRO expired. Petitioner argued that she faithfully performed her duties, that there was no legal obstacle to proceed with summary proceedings, and that the June 25, 2014 decision had not yet attained finality; nonetheless, on August 23, 2017 the CA found petitioner guilty of indirect contempt and imposed a fine, and in denying her motion for reconsideration on April 12, 2018, the CA reasoned that she should have suspended proceedings as a matter of judicial courtesy despite the absence of an injunctive writ. Petitioner elevated the matter to this Court, maintaining that the CA acted without jurisdiction and that she did not willfully defy any final and executory decision.
Issues:
Whether the Court of Appeals had authority to cite petitioner in
indirect contempt of court for allegedly defying its decision in a related
certiorari proceeding.
Ruling:
Ratio:
Doctrine: