G.R. No. L-39584. May 3, 1976.
JORGE P. ROYECA, petitioner, vs. HON. PEDRO SAMSON ANIMAS, Presiding Judge of the Court of First Instance of South Cotabato, Branch I, and the HEIRS OF ADAN DE LAS MARIAS, respondents.

FACTS

Petitioner Jorge P. Royeca was adjudged guilty of direct contempt and sentenced to ten days imprisonment and a fine by respondent Judge Pedro Samson Animas. The contempt citation stemmed from a Motion for Inhibition filed by Royeca in a pending civil case where he was the plaintiff. The motion expressed Royeca’s doubt about the court’s impartiality and surprise at its suggestion of an amicable settlement, implying a failure to dispense equal justice. Royeca and his counsel appeared as ordered, offered an apology, and even filed a motion to withdraw the statements. Despite this, respondent Judge issued the challenged order, which not only found direct contempt but also contained derogatory personal remarks against Royeca, calling him a “self-anointed local tyrant” with a “polluted and stupid mind.”
Respondent Judge, in his comment, justified the order by asserting that the motion was false, malicious, and libelous, designed to degrade the court’s integrity. He emphasized that Royeca’s counsel had admitted the motion tended to “assault the integrity” of the judge. The judge explained his strong reaction by referencing the judicial background of the case, including prior litigation, and argued that the motion arrogantly demanded a favorable order without trial, an attitude he found condemnable in the context of the New Society.

ISSUE

Whether the respondent Judge committed grave abuse of discretion in finding the petitioner guilty of direct contempt and in using intemperate language in the contempt order.

RULING

Yes, the Supreme Court found grave abuse of discretion. The power to punish for contempt must be exercised judiciously and sparingly, with the sole objective of preserving the court’s authority and dignity, not to vindicate personal feelings. While a judge may understandably feel offended by imputations of partiality, the Motion for Inhibition, when objectively appraised, did not constitute direct contempt. Direct contempt requires conduct so offensive as to obstruct judicial administration immediately. The motion’s expressions of doubt and surprise, while perhaps disrespectful, did not rise to this level, especially considering the subsequent apology and withdrawal.
Crucially, the Court condemned the vitriolic and personally insulting language used by the judge in his order. Such epithets were deemed unnecessary, improper, and a deviation from the decorum and restraint required of the judiciary. The contempt power cannot be used as a tool for “character assassination” or to retaliate against a party. By imposing the maximum penalty and coupling it with inflammatory language, the judge allowed personal pique to overshadow judicial temperament, thereby committing grave abuse of discretion. The assailed order was annulled and set aside.