G.R. No. 7928 - Province of Tarlac vs. Gale

The Province of Tarlac constructed a provincial building which housed, on its second floor, a court room for the Court of First Instance along with a judge’s chamber and the clerk’s office.
The dimensions of the court room (approximately 18 by 35 feet) and the office spaces were deemed inadequate for the needs of the court due to crowding and poor acoustics.

The original court room was occupied continuously by the judge and court personnel until late 1910 or early 1911.
During the judge’s absence, the complainants removed the judge’s effects and assigned the judge’s office to an internal revenue agent, thereby excluding the judge from his proper quarters.
A partition was erected across the court room, reducing its usable space by over one-third and allowing clerks and typewriters (with attendant noise and disturbance) to interfere with the judicial proceedings.
The inadequate space led to litigants and witnesses having to stand in corridors or sit on stairs, causing further disorder and hindering proper court proceedings.

The provincial board of Tarlac, according to allegations, repeatedly refused to provide essential supplies and equipment such as proper furniture, typewriters, stationery, stamps, and other office materials required for the effective functioning of the court.
On various occasions, inadequate or worn-out equipment was supplied (e.g., a used secondhand typewriter), and necessary requisitions were unmet despite the apparent availability of unexpended funds in the provincial treasury.

In response to these conditions, the respondent judge issued several orders (notably on March 12, March 14, March 17, and March 28, 1912) directing:

The removal of the partition and unauthorized occupants from the court room.
The provisioning of adequate furniture and equipment to ensure the proper administration of justice.

The orders also included a mandate for the provincial board to furnish a list of necessary items by a fixed deadline and threatened sanctions (including fines and potential imprisonment) for non-compliance.
Procedural posture involved an answer to an order to show cause, a demurrer to the answer, and subsequent stipulations leading to a hearing on March 10, 1913.
The record indicates that the defendant (the judge) based his reliance on the fact that the deficiencies and obstructions materially interfered with the court’s functions and that action was needed to preserve the dignity and effective operation of the judicial process.

Whether the respondent judge exceeded his jurisdiction by unilaterally issuing orders to remove the partition and compel the provincial board to furnish adequate court accommodations and supplies.
Whether the judge’s actions, including ordering expenditures and imposing penalties for contempt, fall within his inherent powers to preserve the effective administration of justice.

Whether the statutory duty imposed on provincial officials to furnish a suitable courthouse and necessary supplies is to be determined solely by the provincial board or if the judge retains the power to decide what is necessary for his court’s proper operation.
Whether the alleged unavailability of funds in the provincial treasury can serve as a valid defense against the court’s order requiring the furnishing of necessities.

Whether ordering sanctions for contempt (notably orders issued without a prior hearing in certain instances) violates due process principles.
Whether the ex parte issuances of the orders, and later the modification (or vacation) of the order threatening punishment without hearing, were procedurally and substantively valid.