G.R. No. 182738 - Capitol Hills Golf and Country Club, Inc. vs. Sanchez

Respondent Manuel O. Sanchez, a stockholder of Capitol Hills Golf & Country Club, Inc., filed a petition on July 1, 2002, to nullify the annual and special meetings of stockholders held on May 21, 2002, and April 23, 2002, respectively.
Petitioners filed an Answer with Counterclaims and a Motion for Preliminary Hearing, which was denied by the Quezon City Regional Trial Court (RTC) on August 9, 2002.
Respondent subsequently filed a Motion for Production and Inspection of Documents, which the court granted on September 10, 2002, ordering the production of specific documents related to the stockholders' meetings.

Petitioners filed a motion for reconsideration regarding the denial of their preliminary hearing, which was denied, leading to further motions and delays in document production.
Respondent filed an Omnibus Motion on October 7, 2002, to compel petitioners to comply with the September 10, 2002 Order, which was reiterated by the RTC in subsequent orders.
Petitioners elevated the case to the Court of Appeals (CA), which denied their petition, affirming the RTC's orders.

Respondent attempted to enforce the September 10, 2002 Order, but inspections were repeatedly postponed due to petitioners' motions for deferment.
The trial court eventually ordered the inspection to proceed, but petitioners failed to comply, leading to further motions from respondent for enforcement.
The case was re-raffled multiple times due to recusal of judges, ultimately landing in RTC Branch 226.

On January 11, 2007, during a scheduled inspection, petitioners produced limited documents, claiming they could not locate others, prompting respondent to file a Manifestation with Omnibus Motion for further compliance.
The RTC issued a Resolution on September 3, 2007, reiterating the September 10, 2002 Order and warning petitioners of potential contempt sanctions for non-compliance.

The CA ruled that the RTC did not commit grave abuse of discretion and that the September 3, 2007 Resolution was a valid reiteration of the previous order.
The appellate court found that petitioners had not been denied due process and that the sanctions threatened were appropriate under the rules governing intra-corporate controversies.

Petitioners contended that the RTC's threatened sanctions were improper and did not align with established legal standards for contempt.
The Court clarified that indirect contempt could be sanctioned for disobedience to lawful court orders and that the RTC's actions were within its authority to enforce compliance.