Case Digest (G.R. No. L-27152) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case at hand is People of the Philippines vs. Brigido G. Estrada, G.R. No. L-27152, decided on November 2, 1982. The appellant, Brigido G. Estrada, was a municipal judge in Pangasinan. He was also the attorney of record for accused Jose Vinluan in Criminal Case No. 21677 before the Court of First Instance of Pangasinan, presided over by Judge Antonio C. Masaquel. A hearing was scheduled for July 28, 1966, at 2:00 PM, as per their agreement among the parties involved. However, due to a prior pre-trial conference for a civil case, the criminal case was called at 2:30 PM instead of the initially scheduled time. When the hearing commenced, it was noted that Vinluan was present but unrepresented, prompting him to call Estrada by telephone. Unfortunately, Estrada failed to answer. As a result of his absence, the court ordered the trial to continue on August 4, 1966. Estrada arrived at the court at 2:45 PM, just 15 minutes after the case was called and announced his readiness. Howe Case Digest (G.R. No. L-27152) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background:
- The case involves Municipal Judge Brigido G. Estrada, who was found guilty of contempt of court by the Court of First Instance of Pangasinan for failing to appear on time at a scheduled hearing for Criminal Case No. 21677.
- Estrada was the attorney of record for the accused, Jose Vinluan, in the said criminal case.
- Scheduling of the Hearing:
- The hearing for Criminal Case No. 21677 was initially scheduled for July 28, 1966, at 2:00 PM.
- Due to a pre-trial conference for Civil Case No. 14566, the criminal case was called at 2:30 PM instead.
- Failure to Appear on Time:
- When the case was called at 2:30 PM, Estrada was not present. The accused, Jose Vinluan, attempted to contact Estrada by phone but received no response.
- The trial court proceeded to reschedule the hearing to August 4, 1966, at 9:00 AM.
- Late Arrival and Contempt Charge:
- Estrada arrived at 2:45 PM, 15 minutes late. He explained that his car had stopped on the way to the courthouse, causing the delay.
- The presiding judge deemed the explanation unsatisfactory and summarily imposed a fine of P50.00 for contempt of court, ordering payment within 24 hours.
- Proceeding with the Trial:
- Despite the contempt charge, Estrada continued to represent his client, and the trial proceeded to its conclusion.
Issues:
- Whether the lower court erred in summarily imposing a fine for contempt without a written charge, considering the alleged contemptuous act constitutes indirect contempt.
- Whether the lower court erred in holding Estrada in contempt without providing him an opportunity to be heard, thereby depriving him of due process.
- Whether the lower court erred in ordering the fine to be paid within 24 hours, given that the order would only become final after 15 days.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)