Case Summary (G.R. No. L-68635)
Grounds for Ilustre’s Motion
Ilustre argued that contempt proceedings require criminal‐style procedure and full evidentiary hearings. She claimed she only sought to investigate an alleged lack of deliberation in a First Division Resolution and that her letters merely requested information on how her case was decided.
Due Process and Opportunity to Be Heard
The Court found both respondents received adequate notice and ample opportunity to present lengthy Answers to the January 29, 1987 show-cause Resolution. Due process does not demand a trial-type hearing when parties may file detailed pleadings.
Evidence of Misconduct and Contempt
The Court relied on:
- The malicious and contemptuous character of Ilustre’s letters to individual Justices.
- Laureta’s active involvement in following up the Tanodbayan complaint and comments to the press.
- Res ipsa loquitur: the nature of the communications themselves demonstrated lack of respect for the judiciary.
Judicial Independence and Separation of Powers
The en banc Resolution reaffirmed that no other branch may challenge or re-weigh the Supreme Court’s collective decisions. Article 204 of the RPC does not cover collegiate courts, and the Anti-Graft Act cannot be invoked to attack “unjust” judicial outcomes.
Factual Matrix Undermining the Motions
- Process‐server affidavits showed Ilustre evaded personal service, and that service on Laureta also reached Ilustre.
- Laureta’s own admission of press engagement contradicted his denials.
- Ilustre’s persistent reliance on unsubstantiated suspicions regarding voting
Case Syllabus (G.R. No. L-68635)
Procedural History
- The Supreme Court promulgated a Per Curiam Resolution on March 12, 1987 finding Atty. Wenceslao Laureta guilty of grave professional misconduct and suspending him indefinitely; and holding Eva Maravilla-Ilustre in contempt, imposing a ₱1,000 fine.
- Atty. Laureta filed a Motion for Reconsideration on grounds of lack of hearing, due process violation, and absence of factual basis for the misconduct charges.
- Ilustre likewise moved for reconsideration, arguing deprivation of due process in contempt proceedings and asserting her actions were lawful and peaceful.
- The Court denied both motions and affirmed the previous suspension and contempt penalty.
Background Facts
- Atty. Laureta was accused of circulating to the press copies of Ilustre’s complaint before the Tanodbayan, resulting in a misleading Daily Express headline.
- He contended he neither authored the press material nor misled the public, and even attempted to cancel a press conference to prevent adverse publicity.
- Ilustre sent identical letters to four Associate Justices inquiring into their votes, alleging she sought a peaceful “investigation” into perceived injustice.
- Court process servers failed to serve Ilustre at her address; service upon Laureta’s wife sufficed for both respondents.
Issues Presented
- Whether the indefinite suspension of Atty. Laureta violated his right to life and due process by suspending him without a “trial-type” hearing.
- Whether Ilustre’s contempt proceedings, treated as quasi-criminal, required full assimilation of criminal procedural and evidentiary rules.
- Whether the respondents were given adequate opportunity to be heard.
- Whether the acts and statements of both respondents amounted to contempt and grave professional misconduct.
Arguments of the Parties
- Atty. Laureta:
- Claimed he was denied a proper hearing and that “hearing” does not necessarily mean