In re laureta

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:

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.

RULING:

Offense of “Knowingly Rendering Unjust Judgment”

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.

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 Court.