Case Summary (G.R. No. 75209)
Petitioners
- Nestlé Philippines, Inc., through the Union of Filipro Employees (G.R. No. 75209)
- Kimberly Independent Labor Union for Solidarity, Activism and Nationalism–Olalia (G.R. No. 78791)
Respondents
- Hon. Augusto S. Sanchez, Minister of Labor and Employment
- National Labor Relations Commission and related parties in the Kimberly case
- Union leaders cited for contempt: Tony Avelino, Lito Payabyab, Eugene San Pedro, Dante Escasura, Emil Sayao, Nelson Centeno, Ernesto Facundo, Fausto Gapuz Jr., Antonio Gonzales
Key Dates
- June 17–July 10, 1987: Intermittent pickets at the Supreme Court Padre Faura gate
- July 10, 1987: En banc resolution to show cause
- July 14, 1987: Hearing on contempt charges
- July 17, 1987: Submission of written manifestations
- September 30, 1987: Resolution promulgated
Applicable Law
- 1987 Philippine Constitution: Freedom of speech and assembly (Arts. III, § 4; XIII, § 3) versus judicial independence and integrity (Art. VIII, § 1)
- Rules on contempt (Rule 71, Sections 1–3, Rules of Court)
- Precedents on extrinsic influence: In re Torres (55 Phil. 799), In re Stolen (216 N.W. 127), In re Kelly (35 Phil. 944)
Factual Background
From June 17 to July 10, 1987, members of the two labor unions conducted intermittent pickets outside the Padre Faura gate of the Supreme Court. They erected makeshift shelters and a kitchen on the sidewalk, obstructed access to judicial offices, littered the premises, displayed placards and red streamers, and used loudspeakers to harangue the Court throughout the day. These demonstrations persisted despite warnings conveyed by Justices Yap and Fernan and by Atty. Espinas that the pickets constituted direct contempt and would jeopardize their petitions.
Procedural History
On July 10, 1987, the Supreme Court en banc issued a resolution:
- Offering the unions the chance to withdraw their pickets.
- Directing union leaders and their counsel to appear on July 14, 1987, to show cause why contempt sanctions should not be imposed.
- Specifically requiring Atty. Espinas to show cause why he should not face administrative discipline.
At the July 14 hearing, the cited individuals, through Atty. Espinas, apologized unreservedly, acknowledged the impropriety of their actions, assured nonrepetition, and manifested willingness to accept any penalty. They explained that the demonstrations were actually spearheaded by PAMANTIK rather than by their own unions. On July 17, they filed written manifestations reaffirming their understanding and commitment.
Issue
Whether the union leaders’ and their counsel’s conduct in picketing and haranguing the Supreme Court in an attempt to influence ongoing cases amounted to contempt of court warranting sanction.
Ruling
The Court accepted the apologies, found that contempt charges were technically established, but exercised leniency and dismissed the charges without imposing sanctions. It warned that future attempts to pressure the Court by demonstrations would be met with the full rigor of the contempt power.
Legal Reasoning
- Contempt and Judicial Independence
- The Constitution vests the judiciary with the exclusive power to adjudicate without external influence (Art. VIII, § 1).
- Courts must proceed “in an orderly manner, free from outside interference obstructive of its functions” (Rule 71, Sec. 1).
- Limits on Rights of Speech and Assembly
- While freedom of speech and assembly are fundamental (Art. III, § 4; XIII, § 3), they do not extend to efforts that “pressure or influence” judicial decision-making. Such efforts lose constitutional protecti
Case Syllabus (G.R. No. 75209)
Factual Background
- From June 17 to July 10, 1987, two labor unions—the Union of Filipro Employees (in G.R. No. 75209) and the Kimberly Independent Labor Union for Solidarity, Activism and Nationalism-Olalia (in G.R. No. 78791)—conducted intermittent pickets before the Padre Faura gate of the Supreme Court building.
- Between July 8 and 10, 1987, picketing intensified: the unions erected temporary shelters on the sidewalk, established a cooking area, and left food containers and trash, disregarding sanitation standards.
- Pickets intermittently obstructed access to the Court’s premises and offices of justices, officials, and employees, employed loudspeakers, waved red streamers and placards, and harangued the Court throughout the day.
- These demonstrations continued despite prior admonitions: Justices Pedro L. Yap and Marcelo B. Fernan had met with union leaders, and Atty. Jose C. Espinas (counsel for the Union of Filipro Employees) was warned that the pickets constituted direct contempt and would bar the Court’s consideration of their petitions.
Citation for Contempt and Show-Cause Order
- On July 10, 1987, the Supreme Court en banc issued a resolution:
- It afforded the unions an opportunity to withdraw their pickets immediately.
- It required the following individuals to appear on July 14, 1987, at 10:30 a.m. to show cause why they should not be held in contempt:
- Tony Avelino, Lito Payabyab, Eugene San Pedro, Dante Escasura, Emil Sayao, and Nelson Centeno (union leaders of the Union of Filipro Employees in G.R. No. 75209) and their counsel, Atty. Jose C. Espinas.
- Ernesto Facundo, Fausto Gapuz, Jr., and Antonio Gonzales (union leaders of the Kimberly Independent Labor Union in G.R.