G.R. No. L-34095. July 29, 1974.
ANECITO DUMALAGAN, ET AL., petitioners, vs. GAUDIOSO PALANGPANGAN, ET AL., respondents.

FACTS

Petitioners Anecito Dumalagan and his co-heirs successfully registered a parcel of agricultural land in their names. Respondents Palangpangan, et al., who were adverse claimants but did not formally oppose the registration, refused to vacate the land after a writ of possession was issued. The land registration court found respondents guilty of contempt for this disobedience, a judgment they appealed to the Court of Appeals. Despite this conviction and subsequent direct court orders, respondents remained on the land, leading the sheriff to demolish their houses. They rebuilt their structures and continued their occupation.
Due to this continuing defiance, Dumalagan initiated a second contempt charge against the same group of respondents. The respondents moved to dismiss this second charge. The Court of Appeals, relying on the syllabus of Heirs of B.A. Crumb vs. Court of Appeals, enjoined the trial of the second contempt charge. It reasoned that the respondents’ pending appeal from their first contempt conviction also constituted an appeal from the underlying eviction order, thus barring a subsequent contempt proceeding for the same refusal to vacate.

ISSUE

Whether a second contempt charge may be tried against respondents for their continuing refusal to obey a court order, notwithstanding the pendency of their appeal from a prior conviction for contempt arising from the initial disobedience of the same order.

RULING

Yes, the second contempt charge may proceed. The Supreme Court reversed the Court of Appeals, holding that the doctrine in Crumb was inapplicable. The Crumb case contemplated a scenario where the occupants were not parties to the original case and thus had no prior opportunity to be heard on the merits of the eviction order. For such persons, an appeal from a contempt conviction inherently challenges the validity of the eviction order itself. Here, however, respondents Palangpangan, et al., were not strangers to the proceedings. They had actively participated by aligning their claim with the Director of Lands in the original land registration case. Consequently, they were bound by the final judgment awarding the land to Dumalagan, and the order of eviction was valid and final as to them.
Their appeal from the first contempt conviction challenged only the factual finding of willful disobedience in that specific instance, not the validity of the eviction order they were duty-bound to obey. The second contempt charge was based on new, separate acts of defiance occurring after the first conviction, including rebuilding demolished houses and explicitly refusing to vacate upon their lawyer’s advice. These constituted distinct contumacious acts. Therefore, the pendency of the appeal from the first conviction posed no legal obstacle to the trial of the second charge for subsequent disobedience. The Court ordered the trial court to proceed with the hearing of the second contempt charge.