Title
Barrera vs. Berrera
Case
G.R. No. L-31589
Decision Date
Jul 31, 1970
Judge Catolico defied a binding Supreme Court ruling, deeming it obsolete, and accused the Court Clerk of improper delegation, leading to a contempt charge for undermining judicial authority.

Case Summary (G.R. No. L-31589)

Background and Requests

The proceedings began with a letter dated September 8, 1969, from the counsel for the plaintiff, which requested the Court of First Instance of Cavite, Branch III, presided over by Judge Catolico, to continue the hearing of a civil case concerning Barrera v. Barrera. The plaintiff had one more witness to present but faced delays due to changes in judges. Judge Catolico's opposition to this request stemmed from his interpretation of Rule 22 of the Rules of Court, which governs adjournments and postponements in trial procedures.

Respondent Judge's Position

In his responses to the Department of Justice, Judge Catolico cited the elapsed period of fourteen months since the trial commenced, arguing that this exceeded the three-month limit set forth in the Rules of Court, leading to a loss of control over the case. He maintained that without written authority from the Chief Justice, the trial could not continue, despite being aware of prior Supreme Court rulings, including the interpretation of similar rules as directory rather than mandatory.

Allegations Against the Court

Judge Catolico further escalated his defiance by accusing the Supreme Court of allowing its Clerk to exercise powers that rightfully belonged to the Chief Justice. His commentary implied misconduct in the handling of his authority and the decisions made by the Supreme Court, suggesting that procedural norms had been disregarded. He posited questions regarding the legitimacy of the Supreme Court's oversight of cases that were not appealed or subjected to certiorari.

Court's Response and Contempt Findings

In light of these defiant assertions, the Supreme Court issued a resolution on November 12, 1969, providing Judge Catolico an opportunity to explain his conduct. His defense reiterated a refusal to recognize the authority of the Supreme Court and dismissed the idea that he was in contempt, claiming ambiguity regarding who the offended party was in the proceedings. Ultimately, his obstinacy led the Court to conclude that disciplinary action was warranted due to his blatant disregard for established judicial authority.

Disciplinary Rationale

The Supreme Court clarified that the basis for imposing disciplinary action was not Judge Catolico's personal opinions or dissent regarding the Court's rulings but rather his reckless and unfounded allegations against the Supreme Court's Clerk. His failur

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