G.R. No. 206691 . October 03, 2016
ATTY. RAYMUND P. PALAD, PETITIONER, VS. LOLIT SOLIS, SALVE V. ASIS, AL G. PEDROCHE AND RICARDO F. LO, RESPONDENTS.

FACTS

Petitioner Atty. Raymund P. Palad, counsel for celebrity Katrina Halili, was the subject of an administrative case before the Integrated Bar of the Philippines (IBP). On December 14, 2012, the IBP Board of Governors issued a Resolution recommending his one-year suspension. Petitioner received a copy on March 8, 2013, and filed a Motion for Reconsideration. On April 23, 2013, respondents Lolit Solis and Ricardo F. Lo, entertainment columnists, published articles in the Filipino Star Ngayon and The Philippine Star, respectively, reporting on petitioner’s alleged suspension. The articles referenced the IBP’s findings and noted his motion for reconsideration was pending.
Petitioner filed this petition to cite respondents for indirect contempt. He alleged the publications violated the confidentiality of proceedings against attorneys under Rule 139-B of the Rules of Court and constituted improper commentary on a pending administrative case. Respondents, in their defense, claimed they received information from a reliable source. They argued the matter was of public interest because petitioner, as a high-profile “celebrity lawyer” in a nationally publicized scandal, was a public figure. They asserted their reports were qualified privileged communication protected by freedom of the press.

ISSUE

Whether respondents are liable for indirect contempt for publishing articles concerning the IBP’s recommended suspension of petitioner while his motion for reconsideration was pending.

RULING

No, respondents are not liable for indirect contempt. The Supreme Court held that for indirect contempt to lie, the act must clearly impede or degrade the administration of justice. The articles in question were mere reports on the IBP’s recommendation for suspension, which is not a final and executory judgment. The Court emphasized that the IBP Board of Governors’ resolution is merely recommendatory to the Supreme Court, which retains exclusive authority to disbar or suspend lawyers. The publications did not discuss the merits of the pending motion for reconsideration nor pressure the Court into a specific ruling; they simply relayed information about a procedural development.
Furthermore, the Court ruled that the confidentiality rule under Rule 139-B applies to the investigation and proceedings before the IBP, not to the result or recommendation itself once it is issued. The IBP’s resolution had already been promulgated and received by petitioner, moving it beyond the strictly confidential investigative phase. Petitioner, by virtue of his voluntary and extensive media involvement as a celebrity lawyer, had become a public figure. Matters concerning public figures, especially those related to their professional discipline when of legitimate public concern, are subject to fair commentary. The respondents’ reports, which were factual and included that a motion for reconsideration was pending, fell within the sphere of protected speech and did not constitute contemptuous interference with judicial functions. The petition was dismissed.