G.R. No. L-27072 January 9, 1970
SURIGAO MINERAL RESERVATION BOARD, ET AL., petitioners, vs. HON. GAUDENCIO CLORIBEL ETC., ET AL., respondents, In Re: Contempt Proceedings Against Attorneys Vicente L. Santiago, Jose Beltran Sotto, Graciano C. Regala and Associates, Erlito R. Uy, Juanito M. Caling; and Morton F. Meads.

FACTS

After the Supreme Court’s adverse decision on July 31, 1968, against respondent MacArthur International Minerals Co., the Solicitor General brought to the Court’s attention statements in pleadings filed by MacArthur’s counsel, suggesting disciplinary action. The Court issued a show-cause order on November 21, 1968. The statements cited included allegations in memoranda signed by Atty. Jose Beltran Sotto describing petitioners’ statements as “false, ridiculous and wild,” “scattershot desperation,” “corrupt on its face,” and “immoral and arrogant,” and accusing petitioners of opportunistically changing their claims. A Third Motion for Reconsideration, signed by Atty. Vicente L. Santiago for himself and purportedly for other counsel, stated the Supreme Court had “overlooked the applicable law due to the misrepresentation and obfuscation of the petitioners’ counsel” and referred to a “gimmick” used by “vulturous executives,” questioning if the Court intended to create a decision that excuses fraud. A Motion to Inhibit filed after judgment, also signed by Atty. Santiago, requested Chief Justice Concepcion and Justice Castro to recuse themselves, alleging the brother of Justice Castro was a vice-president of the favored party and the son of the Chief Justice received a significant government appointment before the decision. The motion included a lengthy critique of the decision, listing “incidents” such as violation of law, deprivation of due process, and causing public losses of $150-$200 million. Atty. Santiago later sought to amend the motion, deleting a paragraph criticizing judges. Atty. Sotto withdrew his appearance, disagreeing with the inhibition motion. Atty. Regala denied authorizing the use of his firm’s name. Atty. Uy claimed he was on leave but permitted his name’s use. A second contempt proceeding arose from a July 14, 1969, motion signed by Atty. Juanito M. Caling, which contained disrespectful language, including calling a Supreme Court statement “absurd” and “a patent falsehood.”

ISSUE

Whether the cited attorneys and individual committed contempt of court through improper conduct in their pleadings and motions.

RULING

The Supreme Court found the cited statements contemptuous. It held that while counsel have great latitude in pleading their client’s cause, they must give due respect to the courts. The statements impugned the Court’s integrity, alleged corruption, implied the Court was a tool of the executive, and used disrespectful and scandalous language, constituting improper conduct tending to obstruct the administration of justice. The Court rejected defenses that statements were taken out of context or were legitimate comments, noting the motion to inhibit was a direct attack on the Court’s honor and objectivity. Regarding the second motion, the language used was held to be clearly contemptuous. The Court ruled:
1. On the first charge: Atty. Vicente L. Santiago and Atty. Jose Beltran Sotto guilty of contempt. Atty. Santiago fined P1,000; Atty. Sotto fined P100. Attys. Graciano C. Regala and Associates and Atty. Erlito R. Uy not guilty.
2. On the second charge: Atty. Vicente L. Santiago, Morton F. Meads, and Atty. Juanito M. Caling guilty of contempt. Atty. Santiago fined an additional P1,000; Morton F. Meads fined P1,000; Atty. Juanito M. Caling fined P200.
Copies of the resolution were ordered forwarded to the Secretary of Justice for action against alien Morton F. Meads and to the Solicitor General for possible disbarment or suspension proceedings against the attorneys.