G.R. No. L-8622; November 7, 1913
THE UNITED STATES, plaintiff-appellee, vs. ENRIQUE JACA, defendant-appellant.

FACTS:
Enrique Jaca, the municipal president and a duly appointed special deputy sheriff of Moalboal, Cebu, received a subpoena to serve upon Protasio Tramada, the complaining witness in Criminal Case No. 2297, The United States vs. Nicolas Godinez. The subpoena required Tramada to appear before the Court of First Instance of Cebu on January 11, 1913. On the evening of January 5, 1913, after Tramada signed a receipt for the subpoena, Jaca asked if he was the complainant against Godinez. Upon Tramada’s affirmative reply, Jaca immediately ordered his arrest and detention in the municipal jail. The stated ground for arrest was Tramada’s failure to secure a cedula (community tax certificate). The complaint for this offense was only formally drawn up and signed by the municipal treasurer the following day, January 6. Tramada was detained until the evening of January 6, when the police sergeant bailed him out so he could fulfill his duty as a witness. Tramada testified that he had nothing to eat during his detention. The justice of the peace noted that he had called Jaca’s attention to Tramada’s subpoena, but Jaca insisted on proceeding with the complaint, suggesting Tramada could post bail. The evidence indicated that Jaca and the accused Nicolas Godinez were friends and political allies.

ISSUE:
Whether the appellant, Enrique Jaca, is guilty of contempt of court for procuring the arrest and detention of a subpoenaed witness under circumstances indicating the purpose was to prevent the witness’s attendance at court, thereby impeding the administration of justice.

RULING:
Yes, the appellant is guilty of contempt of court. The Supreme Court affirmed the judgment of the Court of First Instance convicting Jaca and sentencing him to thirty-five days’ imprisonment and a fine of P100.

The Court held that while a witness is not generally immune from arrest on a valid criminal charge, the power of a court to compel witness attendance is indispensable to its functions. A person who procures the arrest of a witness on a frivolous, fictitious, or false charge, or under circumstances clearly showing the arrest was made in bad faith and without necessity for the due administration of justice, with the object of preventing the witness’s court attendance, is guilty of contempt. Such conduct directly tends to impede the administration of justice.

Based on the trial court’s findings of fact, which the Supreme Court accepted, the evidence clearly established that Jaca acted in bad faith. His real and predominant object in having Tramada arrested and detained at that precise time was to prevent Tramada from testifying against his friend and political ally, Nicolas Godinez. The timing of the arrest, immediately after serving the subpoena and without awaiting the termination of the witness’s duties, and the manner in which the cedula complaint was subsequently formalized, demonstrated that the arrest was not required by public interest but was a deliberate attempt to obstruct judicial proceedings.