Title
IN RE: Vicente Sotto
Case
Decision Date
Jan 21, 1949
A senator-lawyer criticized the Supreme Court in a published statement, accusing it of incompetence and threatening reorganization. The Court found him guilty of contempt, emphasizing the judiciary's inherent power to punish actions undermining its authority, despite claims of free speech and good faith.

Expanded Legal Reasoning Model

Facts:

  • Proceedings Initiation
    • On December 7, 1948, the Supreme Court required Atty. Vicente Sotto to show cause why he should not be punished for contempt for issuing a published statement in connection with its decision in In re Angel Parazo, sentencing Parazo to 30 days’ imprisonment for refusing to divulge a news source under the Press Freedom Law (Republic Act No. 53).
    • The statement, printed in the Manila Times and other newspapers, criticized the Court’s interpretation of the Press Freedom Law as “erroneous,” labeled its majority “incompetent” and “narrow minded,” accused it of “so many blunders and injustices,” and threatened legislative measures to “completely reorganize” the Supreme Court.
  • Procedural History
    • Sotto was given five days plus a ten-day extension to file his answer. His response was filed late but nevertheless admitted; it did not deny authorship or textual accuracy of the statement.
    • A hearing was set for January 4, 1949, later postponed to January 10; Sotto did not appear and the case was submitted for decision.
    • In his answer, Sotto argued the Court lacked statutory power to impose correctional penalties (citing Const. Art. VIII, Sec. 13), and invoked his freedom of speech and good faith, insisting he did not intend to attack the justices’ integrity.

Issues:

  • Contempt and Court Authority
    • Did Sotto’s published statement constitute contempt by tending to obstruct or influence the pending Parazo case and degrade the administration of justice?
    • Does the Supreme Court possess inherent power, independent of statute, to punish for contempt?
    • Is Rule 64 of the Supreme Court Rules (penalizing contempt) valid under the Court’s rule-making power (Const. Art. VIII, Sec. 13)?
    • Are Sotto’s defenses—lack of statutory authority, constitutional freedom of speech, and claimed good faith—sufficient to bar contempt sanctions?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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