Case Summary (G.R. No. 194469)
Conflicting NBI Compliances
Initial NBI manifest claimed the specimen was no longer in custody, having been submitted during Dr. Cabanayan’s trial testimony in 1996. The trial court denied this, noting only photographs of slides were admitted. A 1997 NBI certification by Dr. Bautista affirmed custody. Subsequent NBI explanations blamed miscommunication between officials and a medical technologist.
Petition for Indirect Contempt
Webb filed for indirect contempt, accusing respondents of:
- Impeding justice by losing or misrepresenting the specimen’s status.
- Disobeying the Supreme Court’s April 20, 2010 order.
- Coaching witness Jessica Alfaro to fabricate testimony and identify him wrongly.
Res judicata Does Not Bar Contempt Action
Respondents argued the issue was moot or barred by Webb’s acquittal in Lejano. The Court held res judicata (a civil doctrine) inapplicable to contempt (a sui generis remedy in criminal and civil aspects). There was no identity of parties, issues, or causes of action between the criminal appeal and this contempt proceeding.
Legal Nature and Requirements of Indirect Contempt
Indirect contempt includes:
(a) Misbehavior of court officers;
(b) Disobedience of lawful orders;
(c) Improper conduct obstructing justice.
Civil contempt aims at enforcing a court-ordered duty (requires proof by clear and convincing evidence; intent immaterial), while criminal contempt punishes willful defiance (requires proof beyond reasonable doubt and demonstration of bad faith).
Disobedience of Court Order (Civil Contempt)
Respondents Gatdula, Caabay, Mantaring, Bautista, Cabanayan, Arizala, and Esmeralda failed to produce the specimen despite Supreme Court’s directive. Trial‐court transcripts show repeated promises to bring slides, followed by “I forgot” or absence. Good-faith reliance on third-party information does not excuse civil contempt.
Improper Conduct Allegations (Criminal Contempt)
Webb alleged that Rivera and Herra coached Alfaro to prepare a second affidavit and identify him. Criminal contempt requires willful intent, but the evidence (a third-party hearsay about meetings and photo showing) failed to prove deliberate scheme or bad faith beyond reasonable doubt.
Decision on Disobedience Charges
The Court found respondents Gatdula, Caabay, Mantari
...continue readingCase Syllabus (G.R. No. 194469)
Facts and Background
- The controversy arises from the 1991 Vizconde Massacre, in which Carmela Vizconde and her family were killed, and Hubert Jeffrey P. Webb was charged with rape with homicide.
- Webb sought DNA analysis of the semen specimen taken from Carmela’s cadaver to prove his innocence.
- In an April 20, 2010 Resolution, the Supreme Court granted Webb’s petition and ordered the National Bureau of Investigation (NBI) to facilitate submission of the specimen to the UP Natural Science Research Institute.
- The NBI later filed conflicting reports: it first claimed the specimen was submitted to the trial court in 1996, but the trial court denied receipt of the actual slides, only photographs.
- A 1997 NBI certification by Dr. Bautista confirmed the specimen remained in NBI custody.
- Discrepancies persisted: NBI officers Dr. Cabanayan and Dr. Bautista offered inconsistent explanations regarding the specimen’s whereabouts.
Procedural History
- Webb filed a Motion in the trial court to submit the semen specimen for DNA analysis, which was denied.
- He then obtained a Supreme Court certiorari relief, securing the April 20, 2010 order for DNA testing.
- After the NBI reported the specimen missing, Webb filed a Petition for Indirect Contempt against ten NBI officers for willful disobedience and obstruction of justice.
- While the contempt case was pending, the Supreme Court promulgated the criminal case (“Lejano v. People”), acquitting Webb on December 14, 2010.
- Respondents filed Comments arguing mootness, lack of bad faith, res judicata, and absence of personal involvement.
Petition for Indirect Contempt
- Petition filed under Rule 71 of the Rules of Court against ten NBI officers:
• Magtanggol B. Gatdula (current Director)
• Carlos S. Caabay and Nestor M. Mantaring (former Directors)
• Dr. Renato C. Bautista and Dr. Prospero Cabanayan (Medico-Legal officers)
• Atty. Floresto P. Arizala, Jr. and Atty. Reynaldo O. Esmeralda (compliance officers)
• Atty. Arturo Figueras, Atty. Pedro Rivera, and Agent John Herra - Grounds invoked:
- Disobedience or resistance to the Supreme Court’s April 20, 2010 order.
- Improper conduct tending to impede, obstruct, or degrade the administration of justice.
Arguments of Petitioner
- The semen specimen was never turned over to the trial court; only photographs of slides were offered in evidence.
- Respondent Dr. Cabanayan testified under oath in 1996 that he “forgot” to bring slides and never actually surrendered them.
- Dr. Bautista’s 1997 certification that the slides remained in NBI custody was relied upon but later retracted without evidentiary support.
- NBI officers showed gross negligence in preserving a vital piece of evidence while DNA testing was pending.
- Allega