G.R. No. 128938 - Soriano vs. Court of Appeals

On 7 December 1993, the Regional Trial Court (RTC) of Iba, Zambales, Branch 69, rendered a decision finding Ronald Soriano liable for the death of Isidrino Dalusong.
Soriano was convicted for the crimes of homicide, serious physical injuries, and damage to property through reckless imprudence.
The decision, penned by Judge Rodolfo V. Toledano, imposed a sentence ranging from two (2) years, four (4) months, and one (1) day to six (6) years of prision correccional.

Instead of appealing the RTC decision, Soriano filed an Application for Probation on 12 January 1994.
The RTC granted probation on 8 March 1994 for a period of three to six years.
Among the conditions of probation was the requirement that Soriano indemnify the heirs of Dalusong in the amount of Ninety Eight Thousand Five Hundred Sixty Pesos (P98,560.00).

On 26 April 1994, Provincial State Prosecutor Benjamin A. Fadera moved to cancel the probation, contending that Soriano had failed to pay the indemnity as required under Condition Number 11 of the probation order.
Although the RTC denied the motion to cancel probation, it ordered Soriano to submit a program of payment for his civil liability within ten (10) days.
Soriano’s counsel received a copy of the RTC Order requiring the program of payment on 23 June 1994, yet no program was later submitted.
On 15 August 1994, the RTC issued an Order directing Soriano to explain within ten (10) days why he should not be held in contempt for not complying with the prior Order, and to submit the program of payment.

Instead of complying, Soriano filed a Motion for Reconsideration, alleging he had not personally received the 20 June 1994 Order and asserting financial hardship—claiming unemployment and dependence on his parents, despite evidence that he could afford legal representation.
On 4 October 1994, the RTC ordered the detention of Soriano for ten (10) days for contempt of court, revoked the probation granted on 8 March 1994, and ordered him to serve the original imposed sentence.
Soriano filed a Notice of Appeal on 12 October 1994 specifically challenging the contempt order.
Concurrently, he filed a Petition for Certiorari before the Court of Appeals alleging grave abuse of discretion by Judge Toledano in declaring him in contempt and in revoking his probation.
The Court of Appeals, in its Eighth Division, dismissed the Petition for Certiorari, while the Tenth Division denied his appeal regarding the contempt charge.
Soriano then filed a Petition for Review on Certiorari before the Supreme Court, docketed as G.R. No. 128938, contesting the declaration of contempt.
Prior related proceedings in G.R. No. 123936 (decided on 4 March 1999) had already upheld that the revocation of probation was lawful and proper, leaving the issue of the contempt charge as the sole matter for resolution in the present petition.

Soriano contended that a proper hearing was not afforded him prior to being held in indirect contempt.
He argued that the absence of a hearing violated his right to due process, as the rules for indirect contempt require not only written notice but also an opportunity to be heard in court.

Whether the RTC erred in declaring Ronald Soriano in contempt of court for his failure to comply with its orders without affording him a full opportunity to be heard.

Specifically, whether the RTC's procedure in handling the indirect contempt charge conformed to the requirements of Section 3, Rule 71 of the Revised Rules of Court.

Whether the notice rendered to Soriano, though in writing, was sufficient to meet the dual requirement of both a charge and an opportunity to present a defense before a hearing was conducted.

The proper remedy for a contempt proceeding that takes on a criminal character, and if the absence of an actual hearing invalidates the contempt finding.