G.R. No. 135992 - Eastern Telecommunications Philippines, Inc. vs. International Communication Corp.

An administrative complaint was filed against Justice Angelina Sandoval-Gutierrez of the Court of Appeals and Court Administrator Alfredo L. Benipayo.
In its Resolution dated 29 September 1999, the Court dismissed the complaint and required the complainants to show cause why they should not be punished for contempt.
The language used by the complainants was described as intemperate, offensive, and libelous, aimed at impugning the honor and integrity of Justice Gutierrez and the other members of her division.

Involvement of the United BF Homeowners Association, Inc. (UBFHAI) and Eduardo Bago

UBFHAI, an entity distinct from “United BF Homeowners” (the complainant), submitted a Manifestation/Explanation on 20 October 1999 denying involvement in the filing of the administrative complaint.
The officers and directors of UBFHAI claimed they were not aware of the complaint proceedings, stating that Eduardo Bago, a member of their Board and its elected Secretary, had acted without authorization.
Bago was identified as the actual filer who launched a signature campaign and subsequently filed the complaint with the Office of the Court Administrator on 2 September 1998, and later a follow-up letter-complaint addressed to the Office of the Chief Justice.

The original administrative complaint and the subsequent follow-up complaint allege that Justice Gutierrez unduly delayed the resolution of CA-G.R. SP No. 46624, comparing it unfavorably with the expeditious resolution of Penaranda vs. Caoibes, Jr. (CA-G.R. SP No. 47011).
The allegations imbued a tone of frustration and included inflammatory language that not only questioned the efficiency of the appellate process but also cast aspersions on the integrity of the judicial officers.
Justice Gutierrez, in her comment, criticized the UBFHAI officers for negligence and contended that they could not claim ignorance regarding the complaint, as evidenced by prior public communications and internal Memoranda.

UBFHAI, through resolutions issued by its President and other officers, disavowed the actions of Bago and clarified that no official complaint against the justices had been authorized by the association.
When confronted with the Court’s Resolution, Bago presented additional documents, including a follow-up letter-complaint, purportedly bearing the signatures of several UBFHAI directors/officers—an assertion which the association later refuted.
Subsequently, on 23 October 1999, Bago tendered his resignation from the Board after a resolution by UBFHAI ameliorated his unauthorized actions.

The language in the follow-up complaint was found to degrade and impugn the dignity of Justices Gutierrez and Benipayo as well as the integrity of the judicial process itself.
Accusations included insinuations of deliberate delay and alleged conspiracies, which were deemed to be slanderous and a violation of the standard of respectful criticism expected of litigants.

Whether the use of intemperate, offensive, and libelous language in the letters-complaint constituted indirect contempt of court.
Whether Eduardo Bago’s actions, in light of his unauthorized filing and inflammatory rhetoric, violated the duty of respect owed to the court and its officers.
Whether the separation between the actions of the individual (Bago) and the official stance of UBFHAI could absolve the association of responsibility or mitigate Bago’s conduct.
The extent to which emotional expression and frustration over perceived judicial delays can justify public criticism that borders on contempt.