Case Digest (G.R. No. L-20752) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 68635, decided May 14, 1987, the Supreme Court en banc addressed two consolidated motions for reconsideration arising from its Per Curiam Resolution of March 12, 1987. First, Atty. Wenceslao G. Laureta sought to set aside his indefinite suspension for grave professional misconduct, contending that he was denied a proper hearing, that the misconduct imputed to him—namely, circulating to the press a complaint filed by his former client, Eva Maravilla-Ilustre, before the Tanodbayan—was baseless, and that he had in fact acted to prevent adverse publicity. Second, Eva Maravilla-Ilustre challenged the contempt ruling and P1,000 fine imposed for letters she addressed to individual Justices, arguing that the summary nature of contempt proceedings deprived her of her constitutional right to due process. Both respondents had received a show-cause resolution dated January 29, 1987 and each filed a lengthy written Answer. The motions for reconsideration recited these defenses, d Case Digest (G.R. No. L-20752) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Proceedings Before the Supreme Court, En Banc
- Atty. Wenceslao G. Laureta
- Found guilty of grave professional misconduct in a Per Curiam Resolution dated March 12, 1987, and indefinitely suspended from the practice of law.
- Filed Motion for Reconsideration alleging:
- Suspension without a hearing violated his rights to life and due process.
- Denial of authorship and distribution of complaint copies to the press.
- Lack of basis for imputations of misconduct; efforts to prevent adverse publicity.
- No longer counsel to Ilustre before the Tanodbayan; similarities in pleadings were coincidental.
- Eva Maravilla-Ilustre
- Held in contempt for writing malicious letters to four Associate Justices and ordered to pay a fine of P1,000.
- Filed Motion for Reconsideration alleging:
- Deprivation of due process; contempt proceedings akin to criminal cases requiring trial‐type procedures.
- Legitimate “investigation” into how her case was decided; peaceful attempt to vindicate her rights.
- Course of Proceedings and Service of Process
- Show-cause Resolution (January 29, 1987) gave both respondents full opportunity to answer—Laureta filed a 22-page Answer; Ilustre filed a 19-page Compliance Answer.
- Efforts to serve Ilustre personally at her address of record failed; process server delivered copies to Mrs. Laureta, who accepted them for both respondents.
- Ilustre thereafter filed a Petition for Extension of Time and her Motion for Reconsideration, acknowledging receipt of the Resolution on March 12, 1987.
Issues:
- Procedural Due Process
- Whether Laureta’s suspension and Ilustre’s contempt sanction, imposed without trial‐type hearings, violated their constitutional right to notice and hearing.
- Proof of Misconduct and Contempt
- Whether the acts attributed to Laureta (press leaks, authorship of malicious letters) and to Ilustre (contemptuous letters to Justices) were sufficiently established to warrant suspension and contempt.
- Validity of Service of Process
- Whether service on Laureta’s wife, with actual notice to Ilustre, satisfied due‐process requirements.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)