Case Digest (G.R. No. 186592)
Facts:
Petitioners Governor Enrique T. Garcia, Jr., Aurelio C. Angeles, Jr., Emerlinda S. Talento, and Rodolfo H. De Mesa filed a Petition for Indirect Contempt under Section 3(d), Rule 71 of the Rules of Court against respondent Leo Ruben C. Manrique, publisher/editor of the Luzon Tribune, for an article published January 14 to 20, 2009 alleging that a P20 million bribe procured this Court’s TRO in G.R. No. 185132. The TRO enjoining implementation of a preventive suspension by the Ombudsman was issued by this Court on November 19, 2008.
Issues:
- Whether the article constituted indirect contempt under Section 3(d), Rule 71 of the Rules of Court?
- Whether the constitutional guaranties of freedom of speech and press protected the article?
Ruling:
The Court adjudged respondent Leo Ruben C. Manrique GUILTY of indirect contempt and imposed a fine of Twenty Thousand Pesos (P20,000.00). The Court rejected respondent’s invocation of the constitutional guaranties of freedom of speech and press as a defense to the malicious imputations against the judiciary.
Ratio:
The Court held that publications which tend to degrade the courts and destroy public confidence constitute contempt; Manrique’s article insinuated that the TRO was procured by bribery and thus imputed corruption to this Court, exceeding fair criticism. Relying on the recognized distinction between publications that impede pending proceedings and those that scandalize the courts, and on authorities such as People v. Alarcon and People v. Godoy, the Court found the article lacked social value and was not sheltered by free speech protections.
Doctrine:
- The power to punish for contempt is inherent in courts and serves to preserve the administration of justice.
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