G.R. No. 123332 February 3, 1997
AUGUSTO GATMAYTAN, petitioner, vs. COURT OF APPEALS, and METROPOLITAN BANK & TRUST COMPANY, respondents.

FACTS

Metropolitan Bank & Trust Company (Metrobank) filed an ejectment suit (Civil Case No. 32033) in 1986 against the law firm CIAGLO, where petitioner Augusto Gatmaytan was a partner, for non-payment of rentals. CIAGLO answered, raising defenses including a pending ownership dispute over the property. Instead of litigating these defenses within the ejectment case, Gatmaytan, singly or with his firm, initiated a series of nine separate judicial actions over a decade to challenge the Metropolitan Trial Court’s (MTC) jurisdiction and delay the proceedings.
These actions included a suit for declaratory relief and prohibition in the Regional Trial Court (RTC), which was dismissed for lack of jurisdiction and because the issues were defenses properly raised in the ejectment case. Gatmaytan then filed a petition with the Court of Appeals (CA-G.R. SP No. 14116) to compel the RTC to admit an amended complaint and to stop the MTC proceedings. Simultaneously, he appealed the RTC’s dismissal order (CA-G.R. CV No. 18292), which the CA also dismissed. He subsequently elevated both CA dismissals to the Supreme Court via petitions for review (G.R. Nos. 87891 and 95992), which were denied. He filed further petitions for certiorari and prohibition with the Supreme Court and another petition with the Court of Appeals, all seeking to nullify the MTC’s jurisdiction and orders.

ISSUE

Whether petitioner Augusto Gatmaytan is guilty of contempt of court for his multiplicity of suits that constituted an abuse of court processes and unjustifiably delayed the administration of justice.

RULING

Yes, the Supreme Court found Gatmaytan guilty of contempt. The legal logic is that while the right to litigate is inviolable, it must be exercised in good faith. A lawyer’s duty is to assist in the speedy and efficient administration of justice, not to impede it through frivolous or repetitive proceedings. Gatmaytan’s successive petitions, all essentially challenging the MTC’s jurisdiction over a simple ejectment case where his defenses could have been fully ventilated, constituted a clear abuse of the judicial machinery. His actions were calculated to delay, not to obtain a legitimate remedy, as the jurisdiction of the MTC in ejectment cases is settled law. This misuse of procedural rules to frustrate a lawful proceeding and burden the courts with redundant suits undermines judicial integrity and efficiency. Such conduct transgresses the lawyer’s oath and warrants disciplinary action for contempt to uphold the court’s authority and prevent the abuse of its processes.