Title
Fider-Reyes vs. Everglory Metal Trading Corp.
Case
G.R. No. 238709
Decision Date
Oct 6, 2021
A patent infringement case involving Colorsteel and Everglory escalated when the RTC judge proceeded despite a CA ruling, leading to an indirect contempt petition. The Supreme Court ruled no contempt, citing lack of willful defiance and proper legal compliance.

Case Summary (G.R. No. 238709)

Factual Background

The case originated from allegations that Everglory produced and sold tile roofing panels identical to those patented by Colorsteel Systems Corporation. Colorsteel's president, Jose Rey S. Batomalaque, who owned multiple patents for these designs, issued a cease-and-desist demand to Everglory, which was ignored, leading to a formal complaint. Additionally, a series of motions for extensions and an answer to the complaint were filed by Everglory, which culminated in the case being set for decision prior to a decision made by the Court of Appeals (CA) on June 25, 2014.

Procedural History

After the RTC terminated the hearing on the preliminary injunction application, it found itself in a contentious process where Everglory contested various decisions of the RTC through petitions for certiorari, both yielding delays and complications in the infringement case. Following the expiration of a Temporary Restraining Order (TRO) issued by the CA, the RTC proceeded with the merits, ultimately ruling in favor of Colorsteel.

The Indirect Contempt Case

The situation escalated when Everglory filed for indirect contempt against Judge Fider-Reyes in January 2015, alleging that she continued proceedings despite a restrictive CA decision. The CA, ruling against her, held her guilty of indirect contempt due to perceived defiance of the CA's authority, specifically for failing to uphold judicial courtesy.

Arguments Raised

In her defense, Judge Fider-Reyes claimed that she acted properly by continuing proceedings due to the non-finality of the CA’s ruling and the absence of a restraining order against her actions. The respondent argued that she had intentionally disregarded court orders, thereby justifying the contempt citation.

Court Ruling

The court found merit in Fider-Reyes' petition. It ruled that the CA had erred in citing her for contempt, as the proceedings should not have been interrupted without a final and executory judgment. The court emphasized that judicial courtesy does not equate to a mandatory suspension of proceedings, particularly when contentions were still legally valid and unanswered. The Supreme Court clarified that Judge Fider-Reyes did not act maliciously or with intent to defy higher court rulings, finding that she had complied with legal duties despite ongoing litigation.

Understanding of Contempt

The Court expounded on the nature of contempt, distinguishing between direct and indirect contempt. The contempt accusing Judge Fider-Reyes ultimately lacked foundation as she proceeded under the bel

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