G.R. No. 106087 . January 11, 1995.
ROLITO GO y TAMBUNTING, petitioner, vs. THE COURT OF APPEALS, THE HON. BENJAMIN V. PELAYO, and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

This case originated from a Resolution dated April 7, 1993, where the Supreme Court, in a related petition, denied with finality a motion for reconsideration. In that Resolution, the Court also exercised its disciplinary power over members of the Bar. Petitioner’s counsel, Attys. Raymundo A. Armovit, Miguel R. Armovit, and Rafael R. Armovit, were ordered to pay a fine of P500.00 each for using language in their pleadings that was highly derogatory, offensive, and contemptuous. They were sternly warned that a repetition would be dealt with more severely.
Instead of complying with the order to pay the fine, counsel filed a motion on May 3, 1993, to declare their “administrative conviction” void ab initio and for a hearing en banc. A follow-up motion was filed on January 17, 1994. As of November 10, 1994, a certification from the Cashier confirmed that the fine remained unpaid for over a year and seven months. Due to this contumacious defiance, the Court issued a Resolution on November 28, 1994, ordering warrants for the arrest and five-day detention of the counsel.

ISSUE

Whether the Supreme Court may impose disciplinary sanctions, including arrest, upon counsel for contumacious failure to comply with its final order imposing a fine for contemptuous conduct.

RULING

Yes. The Supreme Court affirmed its inherent power to discipline officers of the court, including the imposition of sanctions for defiance of its lawful orders. The legal logic is anchored on the Court’s constitutional mandate to regulate the practice of law and its inherent power to punish contempt to preserve the integrity of the judicial process and enforce compliance with its directives. The counsel’s initial use of contemptuous language warranted the fine. Their subsequent failure to pay for nearly two years, coupled with filing motions challenging the validity of the final order instead of complying, constituted clear contumacy and a direct challenge to judicial authority. This defiance justified the escalated sanction of ordering their arrest to compel obedience.
However, upon counsel’s eventual payment of the P1,500.00 total fine as shown by a receipt attached to their Omnibus Motion of December 25, 1994, the Court granted their plea to recall the warrants of arrest. Compliance with the monetary penalty rendered the coercive arrest order moot. Nevertheless, for their prolonged and defiant conduct, the Court sternly reprimanded the counsel and reiterated its warning. The ruling underscores that while the Court may exercise restraint, it will not tolerate deliberate disobedience, and compliance, even if belated, does not entirely absolve the contemptuous disregard for its authority.