GR 082027; (December, 1948) (Digest)
G.R. No. 082027. December 3, 1948.
In re Investigation of ANGEL J. PARAZO for alleged leakage of questions in some subjects in the 1948 Bar Examinations.
FACTS
Angel J. Parazo, a reporter for the Star Reporter, published a news item alleging a leakage of questions in the 1948 Bar Examinations, favoring students of a particular private university. The Supreme Court, which administers the Bar Examinations, initiated an investigation. Parazo admitted authoring the article in good faith but refused to reveal his confidential sources, despite repeated appeals by the Court’s investigators and later by a Justice in open court. The Court required him to disclose his sources to enable a proper investigation into the serious allegations affecting the integrity of the Bar Exams and the Court itself.
ISSUE
Whether Parazo’s refusal to reveal his confidential sources constitutes contempt of court.
RULING
Yes. Parazo is guilty of contempt of court and is sentenced to imprisonment for one month. The Court held that the interest of the State in investigating an alleged anomaly in the Bar Examinations, which directly affects the administration of justice and public confidence in the Supreme Court and the Bar, outweighs the journalist’s privilege under Republic Act No. 53 (which protects publishers, editors, or reporters from being compelled to reveal their sources). The law’s exception—when the court finds that “the interest of the State requires the revelation”—applies. The Court distinguished this from a mere matter of public interest, emphasizing that the State’s interest in preserving the purity of the Bar Examinations and the integrity of the Court is paramount. Parazo’s refusal obstructed the Court’s constitutional duty to regulate the practice of law.
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