You are on page 1of 4

In re Laureta and Maravilla v.

IAC (1987)
Summary Cases:

In Re: Wenceslao Laureta vs. Intermediate Appellate Court (IAC) (Resolution) 148 SCRA 382


Contempt of Court, Offense of Knowingly Rendering Unjust Judgment, Judicial Independence, Legal
Ethics, Duty of Lawyer as Officer of the Court, Disciplinary Proceedings against Lawyers


Eva Maravilla-Ilustre wrote a letter to the Justices of the First Division of the Supreme Court alleging that
the dismissal of her case via a minute resolution was promulgated unjustly and in violation of the legal
and judicial ethics. In her letter, she threatened that she will hold a press conference regarding the issue
and requested that the judges disclose the extent of their paricipation in the promulgation of the minute
resolution. She also claims that Justice Yap of the first division was previously the law partner of Atty.
Ordonez, then counsel of the other party, and now the Solicitor General.

The Supreme Court, acting on the letter of Ilustre, explained that when the resolution was issued, Justice
Abad was the presiding justice and Justice Yap had no knowledge of the fact that Atty. Ordonez was the
counsel for the opponent and that Justice Yap later on inhibited himself from the case.

Ilustre then filed a criminal complaint against the Justices before the Tanodbayan for knowingly
rendering an unjust resolution and a complaint charging Justice Yap and Atty. Ordonez of using their
influence in rendering the said resolution.

Atty. Wenceslao Laureta, counsel of Ilustre, allegedly circulated these complaints to the press. In
particular, the headline in the Daily Express read Ordonez, 8 Justices Face Graft Charges making it
appear that the Justices were charged with Graft and Corruption.

The Tanodbayan dismissed the compliant and subsequently, the Supreme Court charged Atty Laureta
and Eva Ilustre and found them guilty of Contempt. Atty. Laureta claims that the order of suspension
issued without hearing was violative of his constitutional right to due process of law making said order
null and void while Ilustre claims that her constitutional right to due process was likewise violated for she
should have been given every opportunity to present her side since contempt proceedings are in the
nature of a criminal proceeding.
Copyright Thinc Office Corp. All rights reserved


Contempt of Court

1. Respondents' reliance on the "privacy of communication" is misplaced. Letters addressed to individual

Justices, in connection with the performance of their judicial functions become part of the judicial record
and are a matter of concern for the entire Court. The contumacious character of those letters constrained
the First Division to refer the same to the Court en banc, en consulta and so that the Court en banc could
pass upon the judicial acts of the Division.

2. The Court is not estopped from initiating contempt proceedings. It must act to preserve its honor and
dignity from the scurrilous attacks of an irate lawyer, mouthed by his client, and to safeguard the morals
and ethics of the legal profession.

3. Respondent Ilustre has transcended the permissible bounds of fair comment and criticism to the
detriment of the orderly administration of justice in her letters addressed to the individual Justices. he
fact that said letters are not technically considered pleadings, nor the fact that they were submitted after
the main petition had been finally resolved does not detract from the gravity of the contempt committed.
The constitutional right of freedom of speech or right to privacy cannot be used as a shield for
contemptuous acts against the Court.

Offense of Knowingly Rendering Unjust Judgment

4. Article 204 of the Revised Penal Code as to "rendering knowingly unjust judgment" refer to an
individual judge who does so "in any case submitted to him for decision" and even then, it is not the
prosecutor who would pass judgment on the "unjustness" of the decision rendered by him but the proper
appellate court with jurisdiction to review the same, either the Court of Appeals and/or the Supreme

5. Said penal article has no application to the members of a collegiate court such as this Court or its
Divisions who reach their conclusions in consultation and accordingly render their collective judgment
after due deliberation. It also follows, consequently, that a charge of violation of the Anti-Graft and
Corrupt Practices Act on the ground that such a collective decision is "unjust" cannot prosper.

Judicial Independence
Copyright Thinc Office Corp. All rights reserved

6. The fundamental principle of separation of powers and checks and balances under a republican form
of government [means] that the three co-equal branches of government, the executive, legislative and
judicial, are each supreme and independent within the limits of its own sphere. Neither one can interfere
with the performance of the duties of the other. Our Constitution "as 'a definition of the powers of
government' placed upon the judiciary the great burden of 'determining the nature, scope and extent of
such powers' and 'when the judiciary mediates to allocate constitutional boundaries, it does not assert
any superiority over the other departments .. but only asserts the solemn and sacred obligation entrusted
to it by the Constitution to determine conflicting claims of authority under the Constitution and to
establish for the parties in an actual controversy the rights which the instrument secures and guarantees
to them.'"

7. To subject to the threat and ordeal of investigation and prosecution, a judge, more so a member of the
Supreme Court for official acts done by him in good faith and in the regular exercise of official duty and
judicial functions is to subvert and undermine that very independence of the judiciary, and subordinate
the judiciary to the executive.

Decisions of the Supreme Court are beyond investigation or inquiry

8. Resolutions of the Supreme Court as a collegiate court, whether en banc or division, speak for
themselves and are entitled to full faith and credence and are beyond investigation or inquiry under the
same principle of conclusiveness of enrolled bills of the legislature.

9. Dissatisfied litigants and/or their counsels cannot without violating the separation of powers relitigate
in another forum the final judgment of this Court on legal issues submitted by them for final determination
to and by the Supreme Court and which fall within the judicial power to determine and adjudicate
exclusively vested by the Constitution in the Supreme Court and in such inferior courts as may be
established by law.

Legal Ethics: Duty of Lawyer as Officer of the Court

10. Atty. Laureta should be reminded that his first duty is not to his client but to the administration of
justice; to that end, his client's success is wholly subordinate; and his conduct ought to and must always
be scrupulously observant of law and ethics. For like the Court itself, "a lawyer is an instrument or
agency to advance the ends of justice.

Disciplinary Proceedings against Lawyers

Copyright Thinc Office Corp. All rights reserved

11. Disciplinary proceedings against lawyers are sui generis

(a) Neither purely civil nor purely criminal, they do not involve a trial of an action or a suit, but are
rather investigations by the Court into the conduct of one of its officers.

(b) Not being intended to inflict punishment, it is in no sense a criminal prosecution. Accordingly,
there is neither a complainant nor a prosecutor therein.

(c) It may be initiated by the Court motu proprio.

(d) Public interest is its primary objective, and the real question for determination is whether or not
the attorney is still a fit person to be allowed the privileges as such.

(e) Hence, in the exercise of its disciplinary powers, the Court merely calls upon a member of the
Bar to account for his actions as an officer of the Court with the end in view of preserving the purity
of the legal profession and the proper and honest administration of justice by purging the
profession of members who by their misconduct have proved themselves no longer worthy to be
entrusted with the duties and responsibilities pertaining to the office of an attorney.

12. The Court imposed upon Atty. Laureta an indefinite suspension from the practice of law, leaving it to
him to prove at some future and opportune time, that he shall have once again regained the fitness to be
allowed to resume the practice of law as an officer of the Courts.

Copyright Thinc Office Corp. All rights reserved