G.R. No. L-5059-60 - People vs. Mendoza

The People of the Philippines, as plaintiff-appellant, filed informations for contempt against Simeon Mendoza and Jose Dizon, defendants-appellees, who were charged for violating interlocutory orders issued by the Tenancy Law Enforcement Division of the Department of Justice.
The interlocutory orders, dated May 23, 1949, commanded Mendoza and Dizon to desist from prohibiting complainant-tenant Dominador Navarro from working his landholding in Mabini, Pangasinan.
Despite the orders, Mendoza and Dizon allegedly refused to comply and continued to prohibit the tenant, prompting the filing of contempt charges (Criminal Cases Nos. 18969 and 18974).

Mendoza and Dizon filed motions to dismiss the contempt informations on grounds that the Tenancy Law Enforcement Division had been abolished effective January 1, 1951, by Executive Order No. 392, transferring its powers and functions to the Court of Industrial Relations.
They further argued that although Commonwealth Act No. 461, as amended by Republic Act No. 44, declared violation of such Department of Justice orders as contempt, it failed to prescribe any penalty for the contempt charged.
The trial court granted the motions and dismissed the cases, ruling:

The contempt referred to was punishable, but no penalty was prescribed by law.
Rule 64 of the Rules of Court, governing contempt proceedings, applies only to contempt of courts, not contempt of administrative officials or bodies.
It was unnecessary to rule on jurisdiction or whether the Court of Industrial Relations might prosecute the contempt after abolition of the Tenancy Division.

The Provincial Fiscal of Pangasinan, through the Solicitor General, appealed the dismissal, contending:

The lower court erred in holding that no penalty existed and that Rule 64 was inapplicable.
Section 580 of the Revised Administrative Code and Commonwealth Act No. 461, as amended by RA 44, together provide remedial and penal measures to enforce lawful orders of the Department of Justice regarding tenancy disputes.
The legislative intent was to impose effective penalties to enforce the Rice Share Tenancy Law orders.

Whether or not the Court of First Instance had jurisdiction to hear and try contempt charges against Mendoza and Dizon for violation of interlocutory orders of the abolished Tenancy Law Enforcement Division.

Whether or not contempt arising from violation of such orders carries a prescribed penalty under Commonwealth Act No. 461, as amended by Republic Act No. 44.

Whether or not Rule 64 of the Rules of Court, governing contempt proceedings, applies to contempt committed against Department of Justice administrative officials.

Whether or not the dismissal of the contempt informations was proper given the abolition of the Tenancy Law Enforcement Division and transfer of its functions to the Court of Industrial Relations.