GR 184487; (February, 2013) (Digest)
G.R. No. 184487; February 27, 2013
HON. MEDEL ARNALDO B. BELEN, in his official capacity as Presiding Judge of the Regional Trial Court, Branch 36, 4th Judicial Region, Calamba City, Petitioner, vs. JOSEF ALBERTS COMILANG, Respondent.
FACTS
State Prosecutor Josef Albert Comilang was cited for contempt by Judge Medel Arnaldo B. Belen for failing to appear at hearings and for the contents of his motions. Comilang challenged the contempt orders via a petition for certiorari before the Court of Appeals (CA) in CA-G.R. SP No. 94069. The CA issued a Temporary Restraining Order (TRO), later a writ of preliminary injunction, enjoining Judge Belen from executing the assailed orders and decision. Despite this injunctive writ, Judge Belen subsequently issued new orders requiring Comilang to explain his failure to post a supersedeas bond and to appear in court, ultimately finding him guilty of indirect contempt again in an Order dated October 1, 2007. Comilang then filed a petition before the CA to cite Judge Belen in contempt for defying the CA’s injunction.
ISSUE
Whether the Court of Appeals correctly found Judge Medel Arnaldo B. Belen guilty of indirect contempt for issuing orders in defiance of its injunctive writ.
RULING
Yes, the Court of Appeals was correct. The Supreme Court affirmed the CA’s finding of indirect contempt against Judge Belen. The legal logic is grounded in the principle that a lawful injunction issued by a superior court must be respected and obeyed. The CA’s TRO and subsequent writ of preliminary injunction in CA-G.R. SP No. 94069 expressly restrained Judge Belen from enforcing his prior contempt orders against Comilang. By proceeding to issue the September and October 2007 orders, which required Comilang to explain his non-compliance with the very acts enjoined and which found him in contempt anew, Judge Belen willfully disobeyed the CA’s lawful order. This disobedience constitutes indirect contempt under the Rules of Court, as it impeded, obstructed, and degraded the administration of justice by disregarding the authority of the appellate court. The Supreme Court emphasized that judges are not exempt from contempt sanctions when they themselves violate court orders, as such acts undermine judicial integrity and the hierarchy of courts.