Case Summary (G.R. No. 68635)
Parties
Petitioner before the Court en banc: Eva Maravilla Ilustre (for contempt).
Respondent-in-discipline: Dean Wenceslao Laureta (officer of the Court).
Key Dates
• 14 May 1986 – Supreme Court First Division dismisses Ilustre’s petition by extended minute-resolution.
• 22 October 1986 – Ilustre sends identical letters to four Justices accusing them of “railroading” her petition.
• 28 October 1986 – En banc “noted” the letters and returned the matter to the First Division.
• 3 November 1986 – Ilustre sends follow-up letters demanding “Yes or No” answers on three minute-resolutions.
• 16 December 1986 – Ilustre files an affidavit complaint with the Tanodbayan charging Justices and Solicitor General with graft.
• 29 January 1987 – Supreme Court en banc issues a show-cause order against Ilustre (contempt) and Laureta (discipline).
• 12 March 1987 – Court en banc resolves to hold Ilustre in contempt and discipline Laureta.
Applicable Law
• 1935 Constitution (in effect prior to ratification of the 1987 Constitution).
• Rules of Court and Canons of Legal Ethics (especially Canon 16).
• Revised Penal Code, Article 204 (knowing rendition of unjust judgment).
• Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), Section 3(e).
Factual Background
Disputes over the estate of Digna Maravilla spanned four separate proceedings: (1) 1971 probate of her 1944 will; (2) 1976 Court of Appeals denial of collateral relatives’ intervention; (3) 1981–1983 partition case and certiorari before the Court of Appeals; (4) 1984–1986 Supreme Court review (G.R. No. 68635). On 14 May 1986 the First Division, reduced to five members, dismissed Ilustre’s petition by extended minute-resolution, invoking res judicata and prior final judgments. Ilustre reacted by writing individualized letters to four Justices, accusing them of bad faith, “railroading” her petition with “hurry/promptitude unequalled” in SC history, and threatening publicity and another forum. En banc noted and returned the letters; Ilustre filed supplemental letters on 3 November 1986. On 16 December 1986 she lodged a complaint with the Tanodbayan alleging “undue injury” and manifest partiality by Justices and Solicitor General, which was widely publicized under banner headlines of “graft charges.”
Contempt and Disciplinary Proceedings
Upon resuming sessions in January 1987, the Supreme Court en banc issued a show-cause order:
- Eva Maravilla Ilustre to explain why she should not be held in contempt for her letters and Tanodbayan complaint that “undermine and degrade the administration of justice.”
- Dean Wenceslao Laureta to explain why he should not face disciplinary action as officer of the Court for abetting and publicizing those same attacks.
Both filed Answers. Ilustre claimed lack of intent to affront, privacy of correspondence, forfeiture of contempt remedy, and estoppel; Laureta denied authorship of the letters, disclaimed involvement in the Tanodbayan complaint, and invoked vindictive reprisal. The Court found both explanations unsatisfactory.
Issues
- Did Ilustre’s letters and Tanodbayan complaint constitute contempt of court by ascribing bad faith and threatening Justices for adverse judicial acts?
- Did Laureta, as officer of the Court, commit grave misconduct by assisting or failing to curb his client’s contemptuous attacks and by orchestrating media dissemination?
Ruling
- Eva Maravilla Ilustre is held in contempt of court. She is fined ₱1,000.
- Dean Wenceslao Laureta is found guilty of grave professional misconduct and suspended indefinitely from the practice of law.
Legal Rationale
• Letters addressed to individual Justices regarding their official functions become part of the judicial record; scurrilous attacks fall outside protected speech and constitute contempt when t
Case Syllabus (G.R. No. 68635)
Facts
- Eva Maravilla Ilustre (petitioner) and Atty. Wenceslao Laureta (her counsel) were involved in a long-running dispute over the estate of their aunt, Digna Maravilla.
- The controversy encompassed multiple proceedings:
• G.R. No. L-23225 (1971) – probate of the 1944 will of Digna Maravilla, admitted by final Supreme Court judgment.
• CA-G.R. No. 05394 (Escolin Decision, 1977) – Court of Appeals denied intervention by collateral relatives, affirmed by this Court in G.R. No. L-46155.
• Civil Case No. X-404 (1979) – petitioners filed for partition and damages in the trial court; judgment by default awarded estates to petitioners and fees to Laureta.
• AC-G.R. SP No. 13680 (Busran Decision, 1983) – Court of Appeals dismissed certiorari petition as appeal was proper remedy, noting the trial court judgment had become final.
• AC-G.R. SP No. 13680 (Javellana Resolution, 1984) – upon motion for reconsideration, the same division reversed itself, set aside default and dismissed petition for partition.
• G.R. No. 68635 (1986) – petition for review of Javellana Resolution, given due course by the First Division, then dismissed by extended minute resolutions dated 14 May, 9 July, and 3 September 1986.
Petitioner’s Correspondence to Justices
- Between 20 and 22 October 1986, Ilustre sent separate letters to Justices Narvasa, Herrera, Cruz, and Feliciano, challenging the First Division’s three minute resolutions as “unjust,” “railroaded,” and issued with “hurry/promptitude unequalled in the entire history of the Supreme Court.”
- She threatened that, absent explanations by individual Justices within a week, she would assume their support for dismissal and pursue “another forum” for justice.
- The letters accused Associate Justice Pedro L. Yap of conflict of interest, alleging his partnership with Solicitor General Sedfrey Ordoñez and failure to record voluntary inhibition.
- Similar letters were sent on 3 November 1986 reiterating the simple inquiry: “Did you or did you not approve the dismissal of our petition under (a) 14 May 1986 minute resolution? (b) 9 July 1986 minute resolution? (c) 3 Sept. 1986 minute resolution? Yes or No.”
First Division Minute Resolutions
- 14 May 1986: Extended minute resolution recalling due-course order and dismissing review for res judicata, affirmed prior Supreme Court and Court of Appeals rulings on probate and heirship.
- 9 July 1986: Denial of motion for reconsideration with finality (“THIS IS FINAL”).
- 3 September 1986: Denial of leave to file second motion for reconsideration; entry of judgment on 28 July 1986.
- All three resolutions were unsigned and adopted the doctrine that multiple final judgments barred relitigation.