G.R. No. 201286 - Tagalog vs. Vda. de Gonzales

The case involves a petition for certiorari and prohibition under Rule 65 of the Revised Rules of Court filed by petitioners Alen Ross Rodriguez and Regidor Tulali.
The petitioners, who held positions as Provincial Prosecutor of Palawan and Prosecutor I respectively, were charged with direct contempt and violation of their oath of office.
The challenged action was the October 13, 2009 Decision rendered by Judge Bienvenido Blancaflor, Acting Presiding Judge of Branch 52, RTC Palawan, in which they were found guilty.

The proceedings stemmed from Criminal Case No. 22240 for arson, People of the Philippines v. Teksan Ami, where Tulali served as the trial prosecutor.
During the pendency of the arson case, Tulali became embroiled in a bribery controversy involving Randy Awayan, a driver under the payroll of the Office of the Governor of Palawan, and Ernesto Fernandez.
To dispel suspicions of wrongdoing, on June 29, 2009, Tulali filed an ex-parte manifestation withdrawing his appearance in the arson case, attaching a copy of an administrative complaint against Awayan (filed by Rodriguez).
The decision in the arson case was rendered the following day (June 30, 2009), acquitting the accused, Rolly Ami.

On July 30, 2009, Judge Blancaflor issued an order summoning Rodriguez to appear for an inquiry regarding his alleged involvement in the administrative complaint and Tulali’s ex-parte filing.
Following further developments, on August 13, 2009, the judge informed the petitioners that proceedings would be instituted against them for direct contempt and for violating their oath of office.
Subsequent to the submission of position papers by the petitioners, Judge Blancaflor issued the assailed October 13, 2009 Decision, which:

Declared both petitioners guilty of direct contempt.
Imposed the penalty of indefinite suspension from the practice of law.
Ordered each petitioner to pay a fine of P100,000.00.
Directed that a public apology be issued, under pain of arrest if not complied with.

The petitioners contended that the contempt proceedings were null and void because their right to due process had been violated.
They argued that they were not properly informed of the charges against them nor given an opportunity to confront witnesses or present evidence in their defense.
The simultaneous conduct of contempt and disciplinary (suspension) proceedings was asserted to be improper and in violation of established legal standards.
The Office of the Solicitor General also manifested that the judge had committed grave abuse of discretion by basing his decision on flawed evidence and erroneous legal interpretations.

Whether the petitioners were deprived of their constitutional right to due process by not being duly informed of the nature and cause of the charges.
Whether the opportunity to confront witnesses and present evidence was denied during the contempt proceedings.

Whether the filing of an ex-parte manifestation by Tulali, undertaken to withdraw from the arson case, falls within the ambit of direct contempt.
Whether Rodriguez, who had no part in the preparation or filing of the ex-parte manifestation, can be held liable for direct contempt.

Whether the penalty of indefinite suspension from the practice of law and the imposition of a P100,000.00 fine exceed the limits prescribed by law for direct contempt.
Whether the punishment conforms to the protective rather than punitive purpose inherent in the exercise of contempt powers.

Whether Judge Blancaflor committed grave abuse of discretion amounting to lack or excess of jurisdiction in handling the simultaneous contempt and disciplinary proceedings.
Whether the failure to issue a proper written charge and to afford the petitioners a full hearing invalidates the imposed sanctions.