G.R. No. 174507 -30; August 3, 2011
ATTY. EMELITA H. GARAYBLAS and ATTY. RENATO G. DE LA CRUZ, Petitioners, vs. THE HON. GREGORY ONG, HON. JOSE HERNANDEZ and HON. RODOLFO PONFERRADA, as Chairman & Members, respectively, 4th Division, Sandiganbayan; and People of the Philippines, Respondents.

FACTS

Petitioners Atty. Emelita H. Garayblas (principal counsel) and Atty. Renato G. De la Cruz (collaborating counsel) represented Gen. Jose S. Ramiscal in criminal cases before the Sandiganbayan. The 4th Division set the pre-trial for April 27, 2006, in Davao City. Atty. Garayblas’s motion to reset was denied. Both petitioners failed to appear at the pre-trial. The Sandiganbayan ordered them to explain why they should not be held in contempt. Atty. Garayblas explained that on April 26, 2006, she suffered from severe headache, body weakness, and sluggishness, with a blood sugar count of 420 and blood pressure of 170/140, and was advised by her doctor to rest, which prevented her from traveling. Atty. De la Cruz explained that he had to appear before the Sandiganbayan Second Division in a related case for the same accused on the same date, attaching a certificate of appearance. The Sandiganbayan 4th Division, in an Order dated June 14, 2006, found their explanations unsatisfactory, noting they belonged to the same law office and should have made arrangements for one to appear, that Atty. De la Cruz should have prioritized the out-of-town hearing, and that Atty. Garayblas failed to submit a medical certificate. It ordered each petitioner to pay a fine of ₱10,000.00. Their motions for reconsideration were denied in a Resolution dated August 10, 2006. Petitioners filed this certiorari petition, alleging grave abuse of discretion.

ISSUE

Whether the Sandiganbayan 4th Division acted with grave abuse of discretion in holding petitioners liable and imposing sanctions for their non-appearance at the pre-trial conference despite their proffered excuses.

RULING

The Supreme Court partially granted the petition. It found that the Sandiganbayan did not commit grave abuse of discretion in holding Atty. De la Cruz liable but did commit grave abuse of discretion in penalizing Atty. Garayblas.
1. As to Atty. De la Cruz: The Court upheld the Sandiganbayan’s finding that his excuse was unacceptable. He failed to exercise prudence in scheduling and should have given priority to the out-of-town pre-trial hearing in Davao City due to the significant expenses incurred by the court. His conflict of schedule was of his own making. The fine of ₱10,000.00 was affirmed.
2. As to Atty. Garayblas: The Court ruled that the Sandiganbayan committed grave abuse of discretion in not accepting her excuse and imposing the fine. The Sandiganbayan itself acknowledged it believed her claim of illness (hyperglycemia and hypertension). Her condition, with symptoms including confusion, fatigue, headache, and vision changes, constituted a valid and acceptable excuse that physically incapacitated her from traveling. The absence of a medical certificate did not render her explanation unsatisfactory under the circumstances. The Court emphasized that while courts have a duty to administer justice promptly, they must also act with understanding and compassion. The Order and Resolution were annulled and set aside insofar as they pertained to Atty. Garayblas, and she was given a stern warning.
The fine against Atty. De la Cruz was sustained; the penalty against Atty. Garayblas was lifted.