Title
Supreme Court
Honasan II vs. Panel of Investigating Prosecutors of the Department of Justice
Case
G.R. No. 159747
Decision Date
Jun 15, 2004
Senator Honasan challenged DOJ's jurisdiction over coup d'état charges, alleging abuse of discretion. Court upheld DOJ's authority, denied contempt motion, citing good faith and due process.

Case Summary (G.R. No. 159747)

Applicable Law

The case is governed by the 1987 Philippine Constitution and procedural rules concerning contempt of court and preliminary investigations.

Procedural Background

The petitioner, Senator Honasan, filed a petition for certiorari against the respondents, alleging grave abuse of discretion in their assumption of jurisdiction over a preliminary investigation into charges of coup d'état against him. The petition sought preliminary injunctive relief, which resulted in the maintenance of the status quo. Subsequently, the Supreme Court rendered a decision affirming the respondents' jurisdiction to conduct said investigation, leading to a motion by petitioner to cite the respondents in contempt for allegedly violating the status quo agreement.

Arguments of the Petitioner

Senator Honasan argued that the respondents had acted in clear contravention of the agreement to maintain the status quo as ordered by the Court. He contended that he retained the right to file a motion for reconsideration until May 7, 2004, and that any order requiring him to submit a counter-affidavit before this deadline would circumvent this right and violate due process. He asserted that the assailed order undermined the ongoing judicial process and cast doubt on the impartial administration of justice.

Arguments of the Respondents

The respondents countered the motion for contempt by asserting that their actions were not contemptuous but rather in compliance with the Court's ruling, aimed at expediting the investigation process. They claimed that their issuance of the assailed order was conducted in good faith and did not reflect any intention to undermine the authority of the Court. The respondents maintained that they had delayed proceedings previously in a show of good faith and were simply fulfilling their mandate to ensure a timely investigation.

Court's Findings on Contempt

The Court clarified the definition of contempt of court, noting it entails acts that demonstrate a willful disregard for the authority and dignity of the court. It emphasized that the power to punish for contempt should be administered exclusively to protect the integrity of the judicial system and only where absolutely necessary. The Court found that the respondents did not manifes

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