Case Summary (G.R. No. 205956)
Press Conference Remarks and Contempt Allegations
During the televised and radio-broadcasted press conference, respondents accused Marantan of “murdering so many innocent individuals,” condemned the Supreme Court for failing to act on the petition filed in 2011, and contrasted the absence of disciplinary measures against Marantan with purportedly overwhelming evidence of his criminal liability. Marantan invoked the sub judice rule and moved to cite respondents for indirect contempt under Section 3(d) of Rule 71, alleging their remarks tended to influence the Supreme Court’s decision and the trial court’s resolution of the pending criminal cases.
Legal Framework: Sub Judice Rule and Indirect Contempt
Under Rule 71, Section 3(d), any improper conduct tending, directly or indirectly, to impede, obstruct, or degrade the administration of justice constitutes indirect contempt. Proceedings for indirect contempt are criminal in nature and require proof of intent. The sub judice rule prohibits public comments and publications that risk prejudicing judicial proceedings, influencing judges, or obstructing justice. The Constitution recognizes freedom of speech but protects the judiciary’s independence. Philippine jurisprudence applies the “clear and present danger” test: only utterances posing an extremely serious and imminent threat to judicial impartiality or administration of justice may be punished as contempt.
Freedom of Speech versus Judicial Independence
The Supreme Court emphasized that while contempt powers safeguard the integrity of judicial proceedings, they must yield in borderline instances to robust public discourse. Criticism of court inaction or pending judicial processes enjoys constitutional protection unless it clearly and imminently threatens the administration of justice. The Court reiterated that freedom of speech and press should not be curtailed merely because opinions pertain to ongoing cases.
Court’s Analysis on Malice and Impending Threat
The Court found no malice on the face of respondents’ statements, as they merely restated arguments from G.R. No. 199462 and highlighted factual allegations underlying their petition. Their remarks did not contain insults to the Court’s dignity, nor did they assert that an unduly long delay ha
...continue readingCase Syllabus (G.R. No. 205956)
Facts of the Case
- Petitioner P/Supt. Hansel M. Marantan is respondent in G.R. No. 199462, a petition filed on December 6, 2011, challenging the downgrading of murder charges to homicide arising from the November 7, 2005 Ortigas incident.
- Respondent Monique Cu-Unjieng LaaO is one of the petitioners in G.R. No. 199462; respondent Atty. Jose Manuel Diokno is her counsel.
- The Ortigas incident involved the fatal shooting of Anton Cu-Unjieng (LaaO’s son) and two companions by police officers, captured on UNTV 37 footage.
- On January 6, 2013, Marantan, as ground commander, oversaw a police-military operation in Atimonan, Quezon, resulting in thirteen fatalities (the Atimonan incident).
- Negative publicity from the Atimonan incident allegedly prompted LaaO, Atty. Diokno, and Ernesto Manzano to hold a televised/radio press conference maligning the Supreme Court’s handling of G.R. No. 199462 and pronouncing Marantan guilty of murder in the Ortigas incident.
- Portions of the press conference aired on ABS-CBN’s TV Patrol on January 29, 2013, containing intemperate comments about police conduct, judicial inaction, and calls for executive intervention.
Procedural History
- G.R. No. 199462 remains pending before the Supreme Court, seeking annulment of the Ombudsman’s downgrading of charges, withdrawal of homicide informations, and refiling of murder charges.
- The underlying criminal cases (Nos. 146413-PSG to 146415-PSG) for homicide are pending before RTC Pasig City, Branch 265.
- Marantan filed a petition in G.R. No. 205956 to cite respondents in contempt for violating the sub judice rule through their press-conference statements.
Issue
- Whether the res