Case Digest (Adm. Case No. 341)
Facts:
The administrative case numbered 341 arose from complaints filed by Delia Murillo against Atty. Nicolas Superable Jr., which commenced on April 1, 1958, when Murillo sent a letter detailing her grievances to the Chief Justice of the Supreme Court. Murillo alleged that Superable, as her employer, had seduced her despite knowing she was a married woman and eventually proposed marriage. They cohabited, resulting in the birth of a child, Nicolas Superable III, whom Superable allegedly abandoned, leading to her filing the complaint. Upon receipt of her letter, Superable was ordered to respond and admitted employing Murillo while denying paternity of the child and asserting that Murillo misrepresented her marital status. He claimed that she had previous relations with other men and alleged the complaint was initiated by the Tacloban Electric Light and Ice Company, which he had criticized in his newspaper "Eagle".
On May 26, 1958, the Court dismissed Murillo's complaint
Case Digest (Adm. Case No. 341)
Facts:
- Background of the Administrative Proceedings
- Delia Murillo, the complainant, filed administrative charges for disbarment/disciplinary action against Atty. Nicolas Superable, Jr., alleging immoral and unethical conduct.
- The basis of the complaint centered on allegations that Superable, while employing her in his office, engaged in an extramarital affair with her, promised marriage, and that their cohabitation resulted in a child.
- Allegations and Admissions in the Main Case
- In her letter to the Chief Justice dated April 1, 1958, Murillo alleged that Superable took advantage of her employment status to initiate a personal relationship, despite knowing she was married.
- Superable admitted hiring her but maintained that she had introduced herself as an unmarried woman upon applying for the job; he also denied being the father of the child, Nicolas Superable III, attributing her subsequent conduct to her intimate relations with other men.
- Superable suggested that Murillo’s complaint might have been instigated by rival interests, notably the Tacloban Electric Light and Ice Company, which he had frequently criticized in his newspaper, the Eagle.
- Incident Leading to the Contempt Proceedings
- Prior to the dismissal of the administrative case (May 26, 1958), Superable sent a letter on May 19, 1958, to the Chief Justice alleging that certain individuals had published his charges in the Eastern Star.
- The publication included Murillo's detailed complaint against him, thereby breaching the confidentiality required by the Rules of Court.
- Superable claimed that the unauthorized publication had caused him mental anguish, reputational harm, and a decline in his legal clientele.
- The Court’s Procedural and Evidentiary Developments
- The Court ordered the five respondents—Dodong R. Herrera, Noning Susaya, Frank Morada, Delia Murillo, and Victoriano Chan—to show cause why they should not be declared in contempt for violating confidentiality.
- Respondents filed their respective answers or supplemental answers, with some admitting the publication was made in good faith to assist in the determination of the main case, while others, like Murillo and Chan, disassociated themselves from the publication.
- Subsequent procedural steps included the filing of memoranda by both Superable and the respondents, depositions taken before Judge Eugenio N. Brillo in Tacloban City, and the submission of documentary evidence such as newspaper issues and affidavits.
- Extraneous Interests and Conflicts
- The rivalries between the parties played a significant role; for instance, Herrera, owner and editor of the Eastern Star, appeared to have motivations rooted in a contest against Superable, given their competition in the legal and journalistic fields.
- Additional conflict arose from personal and professional animosities, including competitions for positions in the Leyte Press Club, which may have exacerbated the decision to publish the charges.
- Timeline and Outcome of Proceedings
- The administrative complaint against Superable was dismissed on May 26, 1958, yet the subsequent publication of the complaint continued to trigger contempt proceedings.
- Actions taken included motions for postponement, requests for the appointment of a commissioner to oversee the evidence, and the eventual scheduling of a hearing that led to the final resolution.
Issues:
- Whether the publication of a confidential complaint against an attorney, as required to be private under Rule 128, Section 10 of the Rules of Court, constitutes a contempt of court.
- The central question was if the dissemination of the charges in a newspaper violated the legal requirement of confidentiality in disciplinary proceedings.
- Whether the motives behind the publication were justified or were driven by extraneous and improper objectives.
- This issue explored if Murillo’s act of providing her complaint for publication was intended solely to embarrass Superable or if it served any legitimate public interest.
- The extent of liability for the secondary actors involved in the publication (i.e., Dodong Herrera and other collaborators).
- Consideration was given to whether ignorance of the confidentiality rules or the influence of personal rivalries could mitigate their responsibility under contempt proceedings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)