Case Summary (G.R. No. 194578)
Key Dates and Procedural History
– November 23, 2009: Ampatuan convoy ambushed and massacred in Maguindanao.
– November 22-23, 2010: Disbarment complaint against Atty. Fortun filed and copies distributed at the Supreme Court.
– February 13, 2013: Decision rendered by the Supreme Court (Second Division).
Applicable Law
– 1987 Constitution, Article III (freedom of speech and of the press).
– Section 18, Rule 139-B, Rules of Court (confidentiality of disbarment proceedings).
– Rule 71, Section 7, 1997 Rules of Civil Procedure (penalties for indirect contempt).
– Privileged-communication doctrine as applied in contempt and libel jurisprudence.
Antecedent Facts
While filing Mangudadatu’s Certificate of Candidacy on November 23, 2009, the convoy was waylaid by armed assailants in Ampatuan municipality, resulting in 57 murders (30 victims were journalists). Multiple murder cases were docketed with the RTC of Quezon City. In November 2010, Mangudadatu et al. filed a disbarment complaint against Atty. Fortun (Bar Matter No. A.C. 8827). On November 22-23, 2010, Atty. Quinsayas distributed copies of the complaint to media representatives. Various media outlets reported or broadcasted the filing, detailing allegations of “abuse of legal remedies” by petitioner.
Contempt Issue
Whether respondents violated the confidentiality requirement of disbarment proceedings (Section 18, Rule 139-B), constituting indirect contempt of court by publishing or broadcasting the filing and substance of the complaint before final resolution.
Media Defendants’ Arguments
– Good faith reporting of a matter of public interest (Maguindanao Massacre, petitioner as public figure).
– Qualified privileged communication; absence of malice or intent to influence judicial proceedings.
– Several media entities denied direct involvement or conspiracy, contending that distribution by Atty. Quinsayas preceded media publication.
– ABS-CBN asserted that ANC programming was produced by Sarimanok Network News (SNN), a separate juridical entity, and that former head Maria Ressa was on terminal leave.
– Philippine Daily Inquirer, Inc. (PDI) claimed content syndication with Inquirer.net but lacked sufficient proof of separate legal personality.
Court’s Analysis on Media Liability
– Disbarment proceedings are ordinarily confidential until final determination; confidentiality serves to protect attorneys from irresponsible allegations and shield the Court’s processes from outside influence.
– Media reporting on matters of legitimate public interest—here, developments connected to the Maguindanao Massacre—enjoys constitutional protection under freedom of the press.
– Petitioner failed to prove bad faith, malice, or a conspiracy among media respondents. Their reporting was fair, accurate, and limited to the newsworthiness of the filing.
– The distribution of the disbarment complaint into the public domain by a complainant did not shield media from responsibility; however, given petitioner’s status as a public figure and the massacre’s notoriety, the reporting was justified.
– ABS-CBN was
Case Syllabus (G.R. No. 194578)
Antecedent Facts
- On November 23, 2009, a convoy bearing relatives of Vice-Mayor Esmael “Toto” Mangudadatu, lawyers, and journalists en route to file a Certificate of Candidacy in Shariff Aguak was intercepted by some 100 armed men at Sitio Malating, Ampatuan town.
- The group was taken hostage, driven to a remote hill in Sitio Magating, Barangay Salman, and systematically executed with automatic weapons; bodies and vehicles were buried in mass graves with a backhoe.
- The atrocity, known as the Maguindanao Massacre, left 57 victims dead—30 of whom were media practitioners.
- Multiple murder cases were filed in the Regional Trial Court of Quezon City (Branches 221), docketed as Criminal Cases Nos. Q-09-162148–172, Q-09-162216–31, Q-10-162652, and Q-10-163766.
- Atty. Philip Sigfrid A. Fortun (petitioner) serves as counsel for Datu Andal Ampatuan Jr., the principal accused.
- In November 2010, Atty. Prima Jesusa B. Quinsayas and other relatives of Mangudadatu filed a disbarment complaint against Fortun before the Supreme Court (Bar Matter No. A.C. 8827), still pending.
- Rule 139-B, Section 18 of the Rules of Court mandates confidentiality of disbarment proceedings until final Supreme Court resolution.
Petitioner's Allegations
- Respondents violated the confidentiality rule by disseminating details of the disbarment complaint against Fortun.
- Media respondents (GMA Network, ABS-CBN, Philippine Daily Inquirer, Philippine Star, ANC broadcast) published articles and aired segments quoting from the confidential complaint.
- Such publications were allegedly timed to coincide with the massacre anniversary, aimed at maligning Fortun’s personal and professional reputation and influencing public opinion and judicial proceedings.
- Petitioner claimed respondents conspired to breach Rule 139-B, exposed the Court and investigators to external pressure, and attacked his presumption of innocence and due process rights.
- Petitioner sought a finding of indirect contempt and corresponding sanctions against all respondents.
Respondents’ Defenses
- GMA Network, Inc.: no print publication; only online posting after distribution by Atty. Quinsayas; no conspiracy or malice; acted in good faith.
- Sophia Dedace (GMA reporter): received a copy of the complaint from Atty. Quinsayas; reported in good faith; believed the matter newsworthy; no