Case Digest (G.R. No. 11715)
Facts:
In re Amzi B. Kelly, G.R. No. 11715, December 21, 1916, the Supreme Court En Banc, Johnson, J., writing for the Court. On March 22, 1916, Ramon Avancena, Attorney‑General for the Philippine Islands, filed a petition in the Supreme Court asking that an order issue directing Amzi B. Kelly to appear and show cause why he should not be punished for contempt arising from a published letter in The Independent (allegedly appearing in the issue of March 4, 1916, and elsewhere referred to as February 24, 1916).Chronologically, the Attorney‑General's petition recited that (a) on February 12, 1916, an information had been filed in the Supreme Court charging Kelly with contempt; (b) on February 17, 1916, the Court found Kelly guilty and sentenced him to six months' imprisonment and a P1,000 fine (with commitment until payment not exceeding two months), and Kelly was imprisoned under that order; and (c) on February 24, 1916, Kelly, through counsel W. H. Lawrence, moved for a rehearing of that contempt proceeding, a motion that was then pending and under advisement by the Court at the time of the publication complained of.
The petition alleged that, while the contempt proceeding and the motion for rehearing were pending, Kelly wrote and caused to be published a lengthy letter addressed to Vicente Sotto and printed in The Independent criticizing the Court and its members, accusing judges of arbitrary and malicious conduct, and asserting that the publication tended to bring the Court into contempt and to influence its action on the pending proceedings. The Attorney‑General therefore prayed for an order to show cause why an attachment should not issue for contempt.
Acting on the petition, the Court, under the hand and seal of its Acting Chief Justice, issued an order on March 22, 1916 directing Kelly to show cause on March 25, 1916. Kelly appeared on March 25, filed a written answer, and presented oral argument, asserting that no statute in the Philippine Islands authorized the Supreme Court to punish him for the alleged contempt and thus attacking the Court's jurisdiction.
After hearing, the Court considered precedent and law regarding inherent contempt powers, found that Kelly had authored and published the letter while the matter was pending, concluded the publication was willful, malicious, and intended to obstruct the administration of justice and to influence the Court, and therefore found him guilty of contempt and imposed an additional sentence of six months' imprisonme...(Pro-only)
Issues:
- Does the Supreme Court of the Philippine Islands have the jurisdiction or power to punish for contempt by publication absent a specific statutory provision?
- Was Amzi B. Kelly guilty of contempt for the publication complained of and subjec...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)