G.R. Nos. 87014-16 September 13, 1989
SALIC B. DUMARPA, MARANAO C. DANGANAN and SAADUDDIN ALAUYA, petitioners, vs. JAMIL DIMAPORO and the COMMISSION ON ELECTIONS, respondents.

FACTS

Petitioners Salic B. Dumarpa (Provincial Fiscal), Maranao C. Danganan (3rd Assistant Provincial Fiscal), and Saaddudin Alauya (Vice-Governor-OIC Governor) of Lanao del Sur were held in contempt and fined by the COMELEC En Banc. The contempt charge stemmed from a legal opinion they issued. After the COMELEC First Division dismissed petitions challenging the proclamation of Jamil Dimaporo as Mayor of Marogong, Lanao del Sur, and while motions for reconsideration were pending before the COMELEC En Banc, Dimaporo sought official recognition. Vice-Governor Alauya referred the matter to the Provincial Fiscal’s office for a legal opinion on who should be recognized as mayor—Dimaporo or the incumbent OIC, Maclis Balt.
The Provincial Fiscal’s office, through Danganan with Dumarpa’s conformity, opined that OIC Maclis Balt should still be recognized. The opinion cited the constitutional provision that motions for reconsideration of a Division decision must be decided by the Commission En Banc, concluding that the First Division’s decision was not yet final and executory. Dimaporo then filed a motion for contempt with the COMELEC, alleging the opinion undermined the COMELEC’s authority and caused confusion. The COMELEC En Banc found the petitioners guilty of contempt for issuing an opinion that supposedly obstructed the implementation of its First Division’s decision.

ISSUE

Whether the COMELEC committed grave abuse of discretion in finding the petitioners guilty of contempt for issuing a legal opinion in their official capacity.

RULING

Yes. The Supreme Court reversed the COMELEC’s contempt ruling. The Court held that contempt powers must be exercised with restraint and only for preservative, not vindictive, purposes. The petitioners, as provincial legal officers, were duty-bound to provide a legal opinion when officially requested by the Vice-Governor. Their opinion was a routine discharge of official function, not an act intended to disrespect or obstruct the COMELEC. The Court found no evidence of any contumacious intent to denigrate the COMELEC’s authority or to willfully defy its processes. The opinion merely expressed a legal interpretation on the finality of a COMELEC Division decision pending reconsideration—a debatable point of law. Disagreement with a legal conclusion, especially one made in good faith in an official capacity, does not constitute contempt. The COMELEC’s finding was an overly sensitive reaction that unjustly penalized public officers for performing their sworn duty. The contempt order was therefore annulled, and the petitioners were absolved.