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In Re: Wenceslao Laureta (1987)

Petitioners: Eva Maravilla Ilustre and Atty. Wenceslao Laureta


Respondents: N/A
Determining whether or not Ilustre and Laureta should be held in contempt for their remarks on
the Supreme Court
SUMMARY: Eva Maravilla Ilustre, in her fourth case before the Supreme Court, has been held
in contempt due to the letters she sent to individual Justices, her efforts to disparage the SC in
the media, and her complaint against them with the Tanodbayan. Atty. Wenceslao Laureta, her
counsel, is judged to have committed acts unbecoming of an officer of the Court, and has been
suspended indefinitely.
FACTS:

Incriminating acts of Eva Maravilla Ilustre: wrote threatening letters to the Justices of the
Supreme Court; filed an Affidavit-Complaint before the Tanodbayan that completely
disregarded facts, circumstances, and legal considerations; instigated the circulation of a
false headline implying graft and corruption charges against Justices
Involvement of Atty. Wenceslao Laureta: likely wrote the threatening letters sent to the
Justices in Ilustres name; likely encouraged Ilustres pursuit of her Affidavit-Complaint
with the Tanodbayan and her disparaging remarks regarding the Justices in her letters
and comments to the media; was responsible for all the acts of his clients

ISSUE/S:

WoN the Justices of the First Division acted in bad faith


o NO. (Ratio: Ilustre has lost three times in court, and by virtue of res judicata, the
Escolin Decision and the Javellana Resolution, which bar her from acquiring
Maravillas properties, serve as final judgment of the case.)
o SC gave ample time and consideration to her petitions, but ultimately held that
they had no merit (as stated in their Banc Decision)
o Justice Yap clarified that he was not aware that his former partner Atty. Sedfrey
Ordoez was the counsel for the respondents, and inhibited himself immediately
upon finding out
o Court is not duty bound to issue signed Decisions all the time, if it deems it
unnecessary
WoN Ilustres and Lauretas actions violate the principle of separation of powers
o YES. (Ratio: In their persistence to overturn detrimental decisions, their threats of
exposing the supposed corruption of the SC to the media, and their unfounded
complaint to the Tanodbayan, Ilustre and Laureta attempted to subject the
judiciary to the executive, which is unjustifiable under separation of powers.)
o Independence of the judiciary is the indispensable means for enforcing the
supremacy of the Constitution

Reciprocity: The decisions of the SC, whether en banc or division, are as credible
as the enrolled bills of the legislature, and therefore beyond investigation or
inquiry; applicable also the the executive

NOTES:
Timeline of Events
1964 Fernandez et al. vs. Maravilla (L-18799)
Mar. 2, 1971 GR No. L-23225
Ilustres first case with the SC
Maravilla will ordered probated
Followed by 2 Motions for Intervention
Mar. 12, 1987 Escolin Decision, Heirs of Pastor Maravilla et al. vs. Hon. Ernesto S. Tengco,
et al. (CA-GR No. 05394)
Ilustre failed to show right to property or interest; ruled to be legally and
completely excluded from Digna Maravillas will
Nov. 9, 1977 GR No. L-46155
Ilustres 2nd case with the SC
Affirmed the Escolin Decision
Feb. 29, 1979 Macandog Decision, Civil Case No. X-404, Court of First Instance (Negros
Occidental)
Filed after death of Maravillas husband (her original heir), against his
heirs, for partition of the properties
Ordered properties back to trunk of origin; ordered damages to be paid
to Ilustre and Laureta
Jan. 21, 1982 GR No. L-58014
Special civil action for certiorari filed by previous cases defendants
(actual heirs)
SC referred it to the Court of Appeals because it dealt with questions of
fact
Jan. 14, 1983 Busran Decision, AC-GR SP No. 13680, Court of Appeals (4th Division)
Dismissed the petition, because judgment attained finality long ago
Reason: had remedy of appeal, not certiorari
Jan. 20, 1984 Javellana Resolution, CA-GR SP No. 13080, Court of Appeals (4th Division)
CA overturned its own decision after the actual heairs filed a Motion for
Reconsideration
Dismissed Ilustres complaint in Civil Case No. X-404 and ordered
Court not to take further action
Oct. 22, 1984 Petition for Review filed by Ilustre
Ilustres 3rd Case with the SC
Denied in extended minute-resolution of 05/14/86 of the SCs First
Division
Civil Case No. X-404 barred by res judicata
Was not a signed decision, just a resolution
May 14, 1986
July 9, 1986 Issuance of SCs minute-resolutions
Sept. 3, 1986
Oct. 20, 1986 Ilustres letters received by Justices Narvasa, Herrera, and Cruz (all Justices of
the SCs First Division)

Oct. 22, 1986


Oct. 28, 1986
Nov. 3, 1986
Dec. 16, 1986
Dec. 26, 1986
Jan. 29, 1987
Feb. 9, 1987
Mar. 12, 1987

Ilustres letter received by Justice Feliciano; letters marked Noted for SC


evaluation (also a Justice of the SCs First Division)
Banc Decision of the Supreme Court
Stated that there was no need to take further action
Similar letters sent to Justices Narvasa, Herrera, and Cruz
Affidavit-Complaint filed by Ilustre with the Tanodbayan
Tanodbayan Decision to dismiss Affidavit-Complaint
SC releases Resolution asking why Ilustre should not be held in contempt
Compliance-Answer by Ilustre
SC holds that Ilustre should be held in contempt and Laureta is suspended
indefinitely