G.R. No. 11715, December 21, 1916
In re: Amzi B. Kelly

FACTS:
On March 22, 1916, the Attorney-General filed a petition in the Supreme Court, alleging that Amzi B. Kelly had committed a new contempt. Kelly had previously been convicted of contempt on February 17, 1916, and sentenced to six months imprisonment and a fine. While his motion for rehearing in that case was still pending before the Court, Kelly wrote and caused to be published in The Independent on February 24, 1916, a letter. In the letter, he made severe accusations against the Court, describing the judges as being “made of mud,” acting with “arrogance,” “knowingly and maliciously perpetrat[ing] a wrong,” and imprisoning him to “terroriz[e] the people and intimidat[e] the press.” He further asserted that the U.S. Supreme Court would reverse the decision and that the U.S. Senate would remove the judges. The Attorney-General contended that this publication was intended to obstruct, interfere with, and influence the Court’s pending action on his motion for rehearing. The Court issued an order for Kelly to show cause why he should not be punished for this contempt.

ISSUE:
Whether the publication of the letter by Amzi B. Kelly, while his motion for rehearing was pending before the Supreme Court, constitutes contempt of court for which he may be punished.

RULING:
Yes, the Supreme Court found Amzi B. Kelly guilty of contempt.

The Court held that it possesses the inherent power to punish for contempt, a power essential to all courts for the protection of their authority and the proper administration of justice. This power exists independently of statute. The publication in question was made while a proceeding (the motion for rehearing) was pending before the Court. The letter’s content was a direct attack on the integrity and motives of the Court, intended to bring it into contempt and ridicule, lower its dignity, and influence its decision on the pending matter. Such publications are considered misbehavior that obstructs the administration of justice, as parties have a right to a trial uninfluenced by outside coercion or publications designed to sway the court.

By admitting authorship and failing to show sufficient cause, Kelly was found to have willfully and deliberately committed contempt. Consequently, the Court sentenced him to an additional six months of imprisonment and a fine of P1,000, to be served consecutively after the completion of his previous sentence.