Case Summary (G.R. No. 168056)
Petitioners and Respondents (Contempt Proceeding)
Proceeding initiated by the Supreme Court (on its own motion after public reports) to hold a public official accountable for statements affecting the Court’s integrity. Contemnor/respondent: Cesar V. Purisima, former Secretary of Finance. Original administrative or substantive cases underlying the TRO involved multiple petitioners and respondents (as reflected in the consolidated docket), but the contempt resolution specifically addresses Purisima’s public statements and subsequent compliance/explanation.
Key Dates
- Newspaper reports attributing statements to Purisima: July 10–12, 2005 (as reproduced by the Court).
- Court’s earlier resolution requiring Purisima to show cause: July 12, 2005.
- Final resolution finding Purisima guilty and imposing a fine: rendered and documented in the Court’s resolution (decision date shown in the docket materials is in 2005).
Purisima’s Compliance and Explanatory Statements
In response to the Court’s show‑cause order, Purisima filed a Compliance stating, in essence: (1) he did not claim or intend to insinuate that the Court was pressured or influenced by President Gloria Macapagal Arroyo or Malacañang in issuing the TRO; (2) he had stated that the President had on several occasions discussed with the economic team the possibility of postponing the implementation of Republic Act No. 9337 (e‑VAT); (3) he was extremely disappointed by the TRO because it impaired the fiscal consolidation program and that his disappointment increased when he perceived insufficient executive effort to have the TRO lifted; and (4) after hearing rumors that executive officials may have been instrumental in procuring the TRO, he inquired of other cabinet officials whether Malacañang had a hand in the issuance — an inquiry he described as within his duty as Finance Secretary and not intended to equate to an allegation that the Court had been influenced.
Press Reports and Statements Attributed to Purisima
The Court reproduced several newspaper excerpts (Philippine Star, The Daily Tribune, Manila Standard Today, Philippine Daily Inquirer, and others) which reported, in varying terms, that Purisima (and other members of the economic team) had hinted, suggested, or expressly stated that Malacañang had influenced or had a hand in the Supreme Court’s grant of the TRO on the e‑VAT. The reports described the TRO as a reason for cabinet resignations and conveyed comments that the administration’s alleged lobbying of the Court was intended to avoid political fallout from rising prices. Some reports included more direct attributions that Purisima “hinted” or “pointed out” that the President had a hand in the TRO.
Court’s Assessment of Purisima’s Explanation
The Court found Purisima’s explanation unsatisfactory. It emphasized that when the media reports first appeared, Purisima did not promptly correct or deny the attributed statements. His later denials came only after the Court issued the show‑cause order, which the Court regarded as untimely and insufficient as a corrective measure. The Court concluded that, by allowing the initial press narrative to stand uncorrected, the public was left with the impression that the TRO’s issuance was the product of executive machinations. That impression, the Court held, placed the Court into dishonor and public contempt, diminished public confidence in the judiciary, promoted distrust in the institution, and assailed the integrity of its members.
Legal Conclusion and Penalty Imposed
The Supreme Court en banc concluded that Purisima’s conduct amounted to indirect contempt of court. The remedy imposed was a fine of Twenty Thousand Pesos (P20,000.00), payable within ten (10) days from finality of the resolution. The resolution reflects full concu
...continue readingCase Syllabus (G.R. No. 168056)
Court, Citation, and Date
- Full citation: 506 Phil. 306 EN BANC.
- G.R. No. 168056, decision dated September 01, 2005.
- The Resolution is rendered by the Supreme Court of the Philippines, En Banc.
- The dispositive portion is a Resolution authored by Justice Austria-Martinez, J.
Parties and Related Docketed Matters
- Principal case captioned: ABAKADA GURO PARTY LIST (FORMERLY AASJAS) OFFICERS SAMSON S. ALCANTARA AND ED VINCENT S. ALBANO, Petitioners, vs. Executive Secretary Eduardo Ermita; Secretary of the Department of Finance Cesar Purisima; Commissioner of Internal Revenue Guillermo Parayno, Jr., Respondents.
- The source material lists multiple related G.R. Nos. and accompanying petitioners and parties, including but not limited to:
- [G.R. No. 168207] Petitioners: Aquilino Q. Pimentel, Jr., Luisa P. Ejercito-Estrada, Jinggoy E. Estrada, Panfilo M. Lacson, Alfredo S. Lim, Jamby A.S. Madrigal, Sergio R. Osmeña III, vs. Executive Secretary Eduardo R. Ermita, Cesar V. Purisima, Guillermo L. Parayno, Jr.
- [G.R. No. 168461] Numerous petroleum dealers, corporations, and individual service station proprietors as petitioners, vs. Cesar V. Purisima and Guillermo L. Parayno, Jr.
- [G.R. No. 168463] Petitioners including Francis Joseph G. Escudero, Vincent Crisologo, Emmanuel Joel J. Villanueva, and others vs. Cesar V. Purisima, Guillermo L. Parayno, Jr., and Eduardo R. Ermita.
- [G.R. No. 168730] Bataan Governor Enrique T. Garcia, Jr., petitioner vs. Executive Secretary Eduardo R. Ermita; Secretary of Finance Margarito Teves; OIC Commissioner Jose Mario Bunag, BIR; and OIC Commissioner Alexander Arevalo, Bureau of Customs.
- The Resolution specifically addresses proceedings concerning a show-cause order against Former Finance Secretary Cesar V. Purisima.
Procedural Posture and Triggering Event
- The Supreme Court issued a Resolution dated July 12, 2005, requiring Former Finance Secretary Cesar V. Purisima to show cause why he should not be held in contempt of court.
- The alleged contempt consisted of conduct that the Court described as placing the Court and its Members into dishonor, disrepute and discredit, and degrading the administration of justice.
- Purisima filed a Compliance (response) to the Court’s show-cause order, which the Court subsequently evaluated.
Purisima’s Compliance — Key Points of His Explanation
- Purisima expressly stated it was not true that he claimed or insinuated that the Supreme Court was pressured or influenced by President Gloria Macapagal Arroyo or Malacañang Palace to issue the Temporary Restraining Order (TRO) in the instant cases.
- He asserted that what he stated was that President Arroyo had on several occasions discussed with the economic team the possibility of postponing the implementation of Republic Act No. 9337 (the Expanded Value-Added Tax or EVAT).
- Purisima acknowledged his belief that the President wanted to postpone implementation of the law, but affirmed he never claimed or insinuated that the Court was influenced or pressured to issue the TRO.
- He admitted to being extremely disappointed when the Court issued the TRO, describing it as a serious setback to the fiscal consolidation program.
- Purisima stated his disappointment increased when he felt the Executive branch was not doing enough to have the TRO lifted.
- At the height of his disappointment, after hearing rumors that Executive officials may have been instrumental in procuring the TRO, Purisima inquired of