G.R. No. 199825 July 26, 2017
BRO. BERNARD OCA, ET AL. AND ST. FRANCIS SCHOOL OF GENERAL TRIAS, CAVITE, INC., Petitioners, vs. LAURITA CUSTODIO, Respondent.

FACTS

This indirect contempt case arose from an intra-corporate dispute within St. Francis School. Respondent Laurita Custodio, an incorporator, filed a complaint to disqualify petitioners Bro. Bernard Oca and Bro. Dennis Magbanua as trustees. During the pendency of this case, the Regional Trial Court (RTC) issued an Order dated October 21, 2002, designating Ms. Herminia Reynante as the exclusive school cashier with authority to collect all fees. The court directed all parties, including petitioner Alejandro Mojica, to turn over previously collected funds to Reynante and to refrain from further collections.
Petitioners allegedly violated this Order. Custodio filed a motion for contempt, alleging that Alejandro Mojica continued to collect school fees at a rural bank and refused to turn over the collected amounts to Reynante. The RTC found petitioners guilty of indirect contempt, a ruling affirmed by the Court of Appeals. The core issue was whether petitioners’ defiance of the RTC’s Order constituted punishable indirect contempt.

ISSUE

Whether the Court of Appeals erred in affirming the petitioners’ conviction for indirect contempt for their failure to comply with the RTC’s October 21, 2002 Order.

RULING

The Supreme Court DENIED the petition and AFFIRMED the conviction for indirect contempt. The legal logic is anchored on the nature and purpose of contempt powers to uphold court authority and ensure orderly administration of justice. The Court clarified that the October 21, 2002 Order was a valid status quo order issued by the RTC in the exercise of its jurisdiction over the intra-corporate case. It was a definitive directive intended to preserve the school’s operations and prevent financial chaos during litigation. Petitioners’ argument that the order was merely an “advice” or a non-binding suggestion was untenable. A court order, once issued, commands compliance regardless of a party’s personal interpretation of its wisdom or legality.
The acts complained of—specifically, the continued collection of fees by Alejandro Mojica in defiance of the court’s explicit designation of Reynante as the sole cashier—constituted “misbehavior in the performance of [their] official functions” under Rule 71, Section 3(d) of the Rules of Court. As officers of the school corporation, petitioners had a duty to obey the lawful directive. Their willful disobedience impaired the court’s authority to issue provisional remedies and maintain order in the proceedings. Contempt does not require a final judgment on the main case; it punishes the disregard of a court’s ancillary orders necessary to protect its jurisdiction and efficacy. The findings of the RTC, affirmed by the CA, that petitioners’ disobedience was willful and calculated, were supported by evidence. Thus, the penalty imposed was proper to vindicate judicial authority.