In Re: Proceedings For Disciplinary Action Against Atty.

Wenceslao Laureta, And Of Contempt

Proceedings Against Eva Maravilla-Ilustre
Separation of Powers, Checks and Balances | per curiam | March 12, 1987
Facts:
In relation to the dismissal of her case (about a dispute involving a large estate), Eva Maravilla-
Ilustre wrote letters to certain Justices accusing them of releasing hurried resolution beyond the limits of
legal and judicial ethics. She alleges that the decision was influenced by Justice Pedro Yap, who was
previously a law-partner of the defense counsel Atty. Ordonez. Furthermore, Maravilla threatened to
expose the case. Later on, she filed a criminal complaint before the Tanodbayan, charging the Justices
with knowingly rendering an unjust Minute Resolution.
Maravilla-Ilustre’s counsel Atty. Wenceslao Laureta allegedly circulated copies of his client’s
complaint to the press, without any copy furnished the Court nor to the said Justices. Tanodbayan later
dismissed the petition.
Atty. Wenceslao Laureta filed a Motion for Reconsideration of the Per Curiam Resolution
promulgated on March 12, 1987, finding him guilty of grave professional misconduct and suspending him
indefinitely from the practice of law; while Eva Maravilla-Ilustre filed a Motion for Reconsideration of
the same Resolution holding her in contempt and ordering her to pay a fine of P1,000.00.
Atty. Laureta maintained that the Order of suspension without hearing violated his right to life
and due process of law and by reason thereof the Order is null and void. He denied distributing copies of
the complaint to the members of the press and that he was not the counsel of Maravilla-Ilustre when she
filed the complaint before the Tanodbayan.
Issue:
1. W/N there was a violation of due process of law as alleged by Atty. Laureta. - NO
2. W/N the Justices acted in bad faith in the dismissal of Maravilla-Ilustre’s case. - NO
3. W/n Maravilla-Ilustre and Laureta disregarded the fundamental principle of separation of
powers and the independence of the Judiciary. - YES
Held:
Due process may be exhibited through any opportunity to be heard and that “hearing” does not
necessarily connote a “trial-type” proceeding. In this case, Atty. Laureta was given sufficient opportunity
to inform the Court of the reasons why he should not be subjected to dispose action and his answer was
weighed by the Court.
The personality of the Solicitor General never came into the picture. It was Justice Abad Santos,
and not Justice Yap, who was Chairman of the First Division when the Resolution of May 14, 1986
denying the Petition was rendered. Thereafter Justice Yap inhibited himself from any participation. The
fact that the Court en banc upheld the challenged Resolutions of the First Division emphasizes the
irrespective of Ilustre’s case irrespective of the personalities involved.
Maravilla-Ilustre and Atty. Laureta allowed suspicion alone to blind their actions and in so doing
degraded the administration of justice. Alleged “investigation” with sympathetic lawyers was utterly
uncalled for. All conclusions and judgments of the Court, be they en banc or by Division, are arrived at
only after deliberation. The fact that no dissent was indicated in the Minutes of the proceedings held on
May 14, 1986 showed that the members of the Division voted unanimously. All deliberations are held
behind closed doors. The Court stated that Article 204 of the Revised Penal Code has no application to
the members of a collegiate Court; that a charge of violation of the Anti-Graft and Corrupt Practices Act
on the ground that a collective decision is unjust cannot prosper; plus the clear and extended dissertation
in the same Per Curiam Resolution on the fundamental principle of separation of powers and of checks
and balances, pursuant to which the Court is “entrusted exclusively with the judicial power to adjudicate
with finality all justifiable disputes, public and private. No other department or agency may pass upon its
judgments or declare them “unjust” upon controlling and irresistible reasons of
public policy and of sound practice.”
Dispositive:
Motion for Reconsideration Denied. Laureta was suspended and Maravilla was fined.