Case Summary (G.R. No. 128938)
Background of Conviction and Probation
On December 7, 1993, the Regional Trial Court (RTC) of Iba, Zambales, Branch 69, convicted Soriano, sentencing him to two years, four months, and one day to six years of imprisonment. Following this, instead of appealing the decision, Soriano filed for probation on January 12, 1994, which was granted on March 8, 1994. Among the probation conditions was the requirement for Soriano to indemnify the heirs of Dalusong in the amount of P98,560.00.
Motion to Cancel Probation
On April 26, 1994, Provincial State Prosecutor Benjamin A. Fadera filed a motion to cancel Soriano's probation for failing to indemnify the heirs as required. Although Soriano contested this motion, the RTC denied the cancellation but required a program for payment of the debt be submitted within ten days.
Failure to Comply with RTC Orders
Despite the RTC's order to submit a payment program, Soriano did not comply. On August 15, 1994, the RTC issued another order asking Soriano to explain why he should not be held in contempt for non-compliance. Rather than adhering to this directive, Soriano filed a motion for reconsideration, claiming he had not received the order personally.
RTC's Contempt Finding and Probation Revocation
The RTC responded to Soriano's non-compliance with an order on October 4, 1994, sentencing him to ten days of detention for contempt and revoking his probation. The RTC expressed doubts about Soriano's intentions to fulfill his civil obligations, particularly since he had engaged legal counsel.
Appeals and Court of Appeals Rulings
Soriano appealed the contempt charge, and the RTC forwarded the records for review by the Court of Appeals. The Court of Appeals ruled in a decision on October 29, 1995, dismissing Soriano's appeal, stating that the RTC did not commit grave abuse of discretion either in finding him in contempt or revoking his probation.
Legal Framework for Contempt
The rule governing indirect contempt, as set out in the Revised Rules of Court, requires prior written charge, an opportunity for the accused to comment, and a hearing. While Soriano was notified of the contempt charge and provided a chance to respond through his motion, the RTC did not hold a hearing, which is a critical element in indirect contempt proceedings.
Requirement of a Hearing in Indirect Contempt
The ruling asserts that an indirect contempt charge necessitates an evidentiary hearing—failure to conduct such a hearing infringes upon the rights of the accused.
...continue readingCase Syllabus (G.R. No. 128938)
Case Background
- The case involves Ronald Soriano (petitioner) who was previously convicted by the Regional Trial Court (RTC) of Iba, Zambales, for the crimes of Homicide, Serious Physical Injuries, and Damage to Property through Reckless Imprudence.
- The RTC, presided over by Judge Rodolfo V. Toledano, sentenced Soriano to imprisonment for a period of two years, four months, and one day to six years of prision correccional.
- Following his conviction, Soriano applied for probation on January 12, 1994, which was granted by the RTC on March 8, 1994, for a duration of three to six years.
Terms of Probation
- Among the conditions of Soriano's probation was the requirement to indemnify the heirs of Isidrino Dalusong, the victim, in the amount of Ninety Eight Thousand Five Hundred Sixty Pesos (₱98,560.00).
- Soriano failed to comply with this condition, prompting Provincial State Prosecutor Benjamin A. Fadera to file a Motion to Cancel Probation on April 26, 1994.
RTC Orders and Non-Compliance
- The Zambales Parole and Probation Office recommended that Soriano be allowed to continue probation but submit a program of payment.
- On June 20, 1994, the RTC denied the Motion to Cancel Probation but required Soriano to submit a program of payment within ten days.
- Soriano's counsel received the RTC's order on June 23, 1994, but no program of payment was submitted.
Contempt Proceedings
- The RTC issued an order on August 15, 1994, requiring Soriano to explai