Court's inherent power to punish disrespect

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The power to punish a person in contempt of court is inherent in all courts to preserve order in judicial proceedings and to uphold the orderly administration of justice. However, judges are enjoined to exercise the power judiciously and sparingly, with utmost restraint, and with the end in view of utilizing the same for correction and preservation of the dignity of the court, and not for retaliation or vindictiveness. It bears stressing that the power to declare a person in contempt of court must be exercised on the preservative, not the vindictive principle; and on the corrective, not the retaliatory, idea of punishment.[1] Such power, being drastic and extraordinary in its nature, should not be resorted to unless necessary in the interest of justice.[2]

In Rodriguez v. Blancaflor,[3] the Supreme Court nullified Judge Blancaflor's order penalizing petitioners for direct contempt on the basis of Tulali's ex-parte manifestation.Tulali filed the Ex-Parte Manifestation withdrawing his appearance in the said case to prevent any suspicion of misdemeanor and collusion. This cannot be construed as contumacious within the purview of direct contempt. This manifestation bore Tulali's voluntary withdrawal from the arson case to dispel any suspicion of collusion between him and the accused. Its filing on the day before the promulgation of the decision in the pending criminal case, did not in any way disrupt the proceedings before the court. Accordingly, he should not be held accountable for his act which was done in good faith and without malice.

Neither should Rodriguez be liable for direct contempt as he had no knowledge of, or participation in, the preparation and filing of the subject manifestation. It was signed and filed by Tulali alone in his capacity as the trial prosecutor in the arson case. The attached complaint against Awayan was filed with the Office of the Palawan Governor, and not with the RTC.

Apparently, Judge Blancaflor's conclusion, that the subject manifestation containing derogatory matters was purposely filed to discredit the administration of justice in court, is unfounded and without basis. There being no factual or legal basis for the charge of direct contempt, it is clear that Judge Blancaflor gravely abused his discretion in finding petitioners guilty as charged.

Direct contempt is any misbehavior in the presence of or so near a court as to obstruct or interrupt the proceedings before the same, including disrespect toward the court, offensive personalities toward others, or refusal to be sworn or to answer as a witness, or to subscribe an affidavit or deposition when lawfully required to do so.[4]

[1] Baculi v. Belen, A.M. No. RTJ-09-2176, April 20, 2009, 586 SCRA 69, 80.

[2]Bank of Philippine Island v. Labor Arbiter Roderick Joseph Calanza, et al., G.R. No. 180699, October 13, 2010, citing Lu Ym v. Mahinay, G.R. No. 169476, June 16, 2006, 491 SCRA 253.

[3] https://www.projectjurisprudence.com/2021/08/gr-no-190171-march-14-2011.html.

[4] Section 1, Rule 71 of the Revised Rules of Court.