G.R. No. L-31589 July 31, 1970
LOURDES BARRERA, plaintiff, vs. LEON BARRERA and FIDELA ANDRES BARRERA, defendants, RE CONTEMPT CATOLICO, respondent.

FACTS

This is a contempt proceeding against respondent Judge Alfredo Catolico of the Court of First Instance of Cavite. The matter originated from a letter by counsel in Barrera v. Barrera, a civil case pending in Judge Catolico’s court, requesting authority for the court to continue the hearing pursuant to Section 3, Rule 22 of the Rules of Court, as the trial had been delayed due to the previous judge’s appointment and a subsequent resetting. The Supreme Court referred the letter to the Department of Justice, which sought Judge Catolico’s comments. In his comments, Judge Catolico asserted that since more than three months had elapsed from the first day of trial, the trial judge lost control of the case and could only dismiss it, despite being aware of the Supreme Court’s ruling in Barrueco v. Abeto which interpreted the rule as directory. He explicitly refused to follow this precedent, calling it obsolete, and questioned the Supreme Court’s policy. He further accused the Supreme Court’s Clerk of improperly delegating the Chief Justice’s authority to extend the trial period and questioned the Supreme Court’s power to authorize a trial judge to continue a case already dismissed. Cited to explain himself, Judge Catolico remained defiant, questioning who the offended party was and stating he could not be charged for expressing an honest opinion different from the Chief Justice’s or for the Clerk’s erroneous letters.

ISSUE

Whether respondent Judge Alfredo Catolico is guilty of contempt for his defiant refusal to follow the Supreme Court’s binding interpretation of the Rules of Court in Barrueco v. Abeto, his disrespectful accusations against the Supreme Court and its Clerk, and his overall obstinate attitude betraying a refusal to apply settled doctrine.

RULING

Yes, the Supreme Court found respondent Judge Alfredo Catolico guilty of contempt. The Court held that his actions—explicitly avowing he was in no mood to accord recognition and respect to a binding decision he considered obsolete, refusing to apply the law as interpreted by the Supreme Court, and hurling unfounded accusations that the Court had improperly delegated authority to its Clerk—betrayed a refusal to abide by settled doctrine. The Court emphasized that lower courts must maintain “a becoming modesty” and that the Supreme Court “has the last word on what the law is.” A judge’s duty is to apply the law as interpreted by the Supreme Court; any personal disagreement does not justify deviation. Given Judge Catolico’s adamant and obdurate stance, the Court had no choice but to find him in contempt. WHEREFORE, respondent Judge Alfredo Catolico was reprimanded by the Court.