G.R. No. 115908 -09 March 29, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANNY GODOY, accused-appellant. JUDGE EUSTAQUIO Z. GACOTT, JR. complainant, vs. MAURICIO REYNOSO, JR. and EVA P. PONCE DE LEON, respondents.

FACTS

This is an incident arising from criminal cases under automatic review. Judge Eustaquio Z. Gacott, Jr. of the Regional Trial Court of Palawan filed a complaint to cite for indirect contempt Mauricio Reynoso, Jr., a columnist, and Eva P. Ponce de Leon, publisher and chairman of the editorial board of the Palawan Times. The complaint is based on an article written by Reynoso in his column “On the Beat,” published in the July 20, 1994 issue. The article discussed the case of Danny Godoy, whom Judge Gacott had sentenced to double death penalty. The article contained statements questioning why the judge did not file charges if death threats from the Godoy family were true, reported rumors about the accused’s personal life, analyzed the potential effects of the Supreme Court’s review on both the accused and the judge’s career, and included a joking warning based on the judge’s television interview. Judge Gacott averred that the article tended to impede, obstruct, belittle, downgrade, and degrade the administration of justice; was disrespectful, discourteous, insulting, offensive, and derogatory; cast aspersions on his integrity and impartiality; and was sub judice. Respondents contended the article was published after the decision, was an exercise of freedom of expression and the press, constituted fair criticism, and was not intended to influence the Supreme Court or impede justice.

ISSUE

Whether the statements in the published article constitute indirect contempt of court.

RULING

No, the statements do not constitute indirect contempt. The Court, after an overall perusal and objective analysis of the article in its entirety, found that the alleged disparaging statements were taken out of context. The article was a reaction to the judge’s own public statements in a television interview. The first portion merely posed a justifiable query regarding the judge’s public accusations of death threats. The second portion reported rumors but explicitly acknowledged uncertainty about their truth. The analysis portion was a fair commentary on the potential consequences of the Supreme Court’s review. The final portion was a reported joke based on the judge’s own interview. The Court held that snide remarks or sarcastic innuendoes do not necessarily reach the level of contumely actionable under Rule 71. The publication did not transcend the legal limits for editorial comment and criticism, and no substantive evil of extreme seriousness with a high degree of imminence was shown to warrant punishment for contempt or to disregard constitutional guarantees of free speech and press. The complaint was dismissed.