G.R. No. 150794 ; August 17, 2004
ATTY. ROMEO B. IGOT, petitioner, vs. COURT OF APPEALS and MANILA ELECTRIC COMPANY (MERALCO), respondents.

FACTS

Petitioner Atty. Romeo Igot had a service contract with respondent MERALCO. In 1998, he discovered his electric meter had stopped functioning. After receiving no reply to his request for inspection, he was later billed over P111,000.00, accused of meter tampering under Republic Act No. 7832 , and threatened with disconnection. Igot filed a complaint for damages with an application for a preliminary injunction in the Regional Trial Court (RTC). The RTC initially issued a Temporary Restraining Order (TRO) and later granted a writ of preliminary injunction. However, MERALCO disconnected his power supply in July 1999. Igot paid under protest to secure reconnection. Subsequently, the RTC dismissed his complaint for repeated failure to appear at hearings.
Igot filed a special civil action for certiorari with the Court of Appeals (CA) to nullify the RTC’s dismissal. On August 24, 2001, MERALCO again disconnected Igot’s electricity at 11:00 a.m. The CA, later that same day at around 3:45 p.m., issued a resolution enjoining the RTC from proceeding and ordering MERALCO to cease and desist from disconnecting Igot’s supply. The CA later issued a writ of preliminary mandatory injunction ordering MERALCO to restore the service. Alleging non-compliance, Igot filed the instant petition for mandamus with the Supreme Court to compel MERALCO to obey the CA’s writ and an omnibus motion to cite MERALCO’s officers and lawyers in contempt.

ISSUE

Whether the Supreme Court should grant the petition for mandamus to compel compliance with the Court of Appeals’ writ of preliminary mandatory injunction and whether it can hold MERALCO’s officers in contempt for alleged disobedience.

RULING

The Supreme Court dismissed the petition for mandamus as moot and academic and denied the omnibus motion to cite respondents in contempt. The legal logic is anchored on the principle of jurisdiction over contempt proceedings. The Court found that MERALCO had already reconnected Igot’s electric service on September 10, 2001, thereby rendering the mandamus petition seeking to compel that very act without purpose. On the contempt charge, the Court held that the power to punish for contempt for disobedience of a court order is exclusively vested in the court that issued the order. This is because contempt proceedings are sui generis, intended to enable a court to compel obedience to its own judgments, orders, and processes. The Court of Appeals, which issued the writ of preliminary mandatory injunction, is the “court contemned” and thus possesses the sole and preferential right to determine whether a contempt was committed and to impose any sanction. The Supreme Court, absent any showing that the contempt was committed against its own authority, lacks jurisdiction to adjudicate the alleged violation of the CA’s order. Therefore, Igot’s proper recourse was to file the charge for indirect contempt with the Court of Appeals itself.