Case Digest (A.M. No. 16-03-10-SC)
Facts:
Re: News Report of Mr. Jomar Canlas in The Manila Times Issue of 8 March 2016, A.M. No. 16-03-10-SC, February 8, 2021, the Supreme Court En Banc, Carpio, J., writing for the Court.On 8 March 2016, The Manila Times published an article by its senior reporter Jomar Canlas alleging that justices of the Supreme Court were offered P50 million each to disqualify Senator Grace Poe in the then-pending disqualification proceedings. The article recounted two alleged attempts to buy votes, named categories of persons purportedly behind the attempts (a female lawyer formerly of Malacañang, a Liberal Party member, and a businessman close to the President and standard-bearer), quoted unnamed “well-placed sources” and an unnamed justice who allegedly said the Court “will not bow to any pressure,” and compared the alleged offer to alleged past offers during the impeachment of Chief Justice Corona.
On 15 March 2016 the Court, citing that certain statements and innuendoes in Canlas’s report “tend, directly or indirectly, to impede, obstruct, or degrade the administration of justice,” directed Canlas to explain why he should not be sanctioned for indirect contempt under Section 3(d), Rule 71 of the Rules of Court. Canlas sought and was granted extensions, and on 22 April 2016 filed an explanation asserting public interest, civic duty, good faith, unsuccessful attempts to secure named justices’ responses, and an apology for any unflattering innuendoes.
The Court considered constitutional free-press protections (Section 4, Article III, 1987 Constitution) and prior jurisprudence on the media’s watchdog role and limits to free expression where the integrity of the judiciary is implicated (including In the Matter of the Allegations Contained in the Columns of Mr. Macasaet; Zaldivar v. Sandiganbayan; Cabansag v. Fernandez; and In Re Emil P. Jurado). En Banc, the Court found Canlas’s article misleading, sensationalized, insufficiently verified, and likely to create doubt about individual justices and the Court as an institution given the close votes in the Poe cases. The ...(Pro-only)
Issues:
- Whether the publication by Jomar Canlas constitutes indirect contempt of court under Section 3(d), Rule 71 of the Rules of Court.
- Whether the sanction imposed (severe reprimand) was appropriate in light of the constitutional protection of freedom of spee...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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