G.R. No. 150949 . June 21, 2007.
JUDGE DOLORES L. ESPAÑOL, petitioner, vs. ATTY. BENJAMIN S. FORMOSO and SPOUSES BENITO SEE and MARLY SEE, respondents.

FACTS

Sharcons Builders Philippines, Inc. (Sharcons) filed a complaint for quieting of title before the Regional Trial Court (RTC), Branch 90 in Dasmariñas, Cavite, presided by Judge Dolores L. Español. The complaint involved a property dispute where Sharcons claimed ownership based on a Transfer Certificate of Title (TCT) derived from a sale. During the proceedings, Judge Español, upon reviewing records from a separate case (Civil Case No. 623-92) decided by another RTC branch in Imus, Cavite, concluded that the title and supporting documents used by Sharcons were spurious.
Consequently, in an Order dated July 9, 2001, Judge Español declared Sharcons’ president, treasurer, and its former counsel, Atty. Benjamin Formoso, guilty of direct contempt of court for allegedly using falsified documents. She ordered their incarceration for ten days and issued warrants of arrest. Respondents were detained but subsequently filed a petition for a writ of habeas corpus with the Court of Appeals, which granted the petition and nullified the contempt order and arrest warrants.

ISSUE

Whether the Court of Appeals correctly nullified the Order finding respondents guilty of direct contempt of court.

RULING

Yes, the Court of Appeals was correct. The Supreme Court affirmed the appellate court’s decision, ruling that Judge Español committed a grave error in finding respondents guilty of direct contempt. Direct contempt involves misconduct committed in the presence of or so near the court as to obstruct justice, and the power to punish summarily must be exercised with caution. Here, the alleged use of falsified documents was not committed in the immediate view and presence of the court. The determination of falsity required examination of evidence and judicial notice of a decision from another case.
Critically, Judge Español improperly took judicial notice of the findings in a decision from another RTC branch (Civil Case No. 623-92). Judicial notice is limited to facts so notorious or within the court’s official knowledge that they require no proof. Courts cannot take judicial notice of the contents of records in other cases, even if pending in the same court. By relying on the findings of another court to conclude that documents were falsified, Judge Español conducted a factual evaluation inappropriate for a summary contempt proceeding. The proper course was a full-blown trial on the issue of falsification. Therefore, the contempt order was issued without legal basis, and the writ of habeas corpus was properly granted. The petition was denied.