Case Digest (G.R. No. 68635) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 68635, decided en banc on March 12, 1987 under the 1987 Constitution, the Supreme Court tackled contempt and disciplinary proceedings arising from inherited‐estate litigation spanning several petitions. Petitioner Eva Maravilla Ilustre had her petition for review dismissed by minute resolutions of the First Division dated May 14, July 9, and September 3, 1986, on grounds of res judicata and finality of prior decisions regarding the will and heirship of her aunt, Digna Maravilla. Aggrieved, Ilustre, through counsel Dean Wenceslao Laureta, sent letters (October 20 and 22, 1986, and again on November 3, 1986) to individual Justices of the Supreme Court—Andres R. Narvasa, Ameurfina M. Herrera, Isagani A. Cruz, Florentino P. Feliciano, and Pedro L. Yap—accusing them of “railroading” her petition, threatening to bring the case “before another forum,” and demanding admissions of participation in the minute resolutions. Ilustre later filed an affidavit complaint with the Tan Case Digest (G.R. No. 68635) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- Original Estate Proceedings
- 1944 will of Digna Maravilla probated by this Court (G.R. No. L-23225, 1971).
- Intervention denied by Court of Appeals (CA-G.R. No. 05394-R, “Escolin Decision”, affirmed Nov. 9, 1977).
- Subsequent Actions on Estate
- Civil Case X-404 for partition and damages in CFI Negros Occidental (Macandog Decision, 1981).
- Certiorari petition referred to CA (G.R. No. L-58014); Fourth Division dismissed (Busran Decision, Jan. 14, 1983), later reversed on reconsideration (Javellana Resolution, Jan. 20, 1984).
- Petition for review before SC denied in extended minute resolution (May 14, 1986) for res judicata.
- Correspondence and Complaints
- Letters by Eva Maravilla-Ilustre (Oct. 20 & 22, 1986)
- Sent to Justices Narvasa, Herrera, Cruz, Feliciano, attacking First Division’s minute resolutions as “unjust” and threatening another forum.
- Alleged misconduct of Justice Yap and Solicitor General Ordoñez for non-inhibition and influence.
- En banc Referral and Resolution (Oct. 28, 1986)
- First Division “noted” letters, referred en banc.
- En banc upheld Division’s findings: Justice Yap inhibited, decisions unanimous, no bad faith.
- Second Letters (Nov. 3, 1986)
- Reiterated simple yes/no inquiry on minute resolutions, threatened press conferences.
- Contempt and Disciplinary Proceedings
- Affidavit Complaint before Tanodbayan (Dec. 16, 1986)
- Ilustre charged Justices and Ordoñez with graft, unjust decisions under R.A. 3019 and RPC Art. 204.
- Reported leaks to press, sensational headlines.
- Tanodbayan Resolution (Dec. 26, 1986)
- Dismissed complaints against most Justices; continued evaluation of some charges.
- Furnished copy to Atty. Wenceslao Laureta, counsel for Ilustre.
- SC Show-Cause Order (Jan. 29, 1987)
- Directed Ilustre and Laureta to explain alleged contempt and professional misconduct.
- Compliance and Answers (Feb. 1987)
- Ilustre denied intent to affront Court, invoked privacy, alleged vindictiveness.
- Laureta disclaimed involvement, claimed to have dissuaded press conference and upheld Court’s dignity.
Issues:
- Did Eva Maravilla-Ilustre’s letters and related acts constitute contempt of Court?
- Did Atty. Wenceslao Laureta commit professional misconduct warranting disciplinary action?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)