G.R. No. 90083 October 4, 1990
Khalyxto Perez Maglasang, accused-petitioner, vs. People of the Philippines, Presiding Judge Ernesto B. Templado (San Carlos City Court), Negros Occidental, respondents.

FACTS

The Supreme Court initially dismissed the petition for certiorari filed by petitioner Khalyxto Perez Maglasang, through counsel Atty. Marceliano L. Castellano, due to non-compliance with procedural requirements under Circular No. 1-88, specifically the non-payment of legal fees and the non-submission of required duplicate copies of the assailed decision and orders. The Court subsequently denied with finality Atty. Castellano’s motion for reconsideration, which still lacked the certified copies of the questioned orders. Months later, the Court received a copy of a complaint filed by the accused, through Atty. Castellano, with the Office of the President. This complaint accused the Justices of the Court’s Second Division of “biases and/or ignorance of the law” and knowingly rendering unjust judgments, using intemperate and scandalous language.
The complaint alleged the Justices were “Marcos appointees” whose common intention was “to sabotage the Aquino Administration” and rob the people of genuine justice. It described the Court’s dismissal as based “more of money reasons” and accused the Justices of being “inconsiderate, extremely strict and meticulous to the common tao.” For this conduct, the Court required Atty. Castellano to show cause why he should not be punished for contempt or disciplined. In his opposition, he insisted the complaint was mere “constructive criticism” and controversially argued that the Justices, being named respondents in his administrative complaint, had lost jurisdiction to cite him for contempt.

ISSUE

Whether Atty. Marceliano L. Castellano is guilty of contempt of court and of improper conduct as a member of the Bar for filing a baseless and scurrilous administrative complaint against Supreme Court Justices before the Office of the President.

RULING

Yes, Atty. Castellano is guilty of both contempt and gross misconduct. The Court emphasized that a lawyer’s right to criticize the judiciary must be exercised responsibly, with bona fide intentions, and within the bounds of propriety and respectful language. The statements in the complaint, which imputed corrupt and politically motivated intentions to the Justices, far exceeded the limits of fair criticism. They constituted a direct assault on the integrity and honor of the Court, calculated to undermine public confidence in the administration of justice. Such baseless and malicious accusations are inherently contemptuous.
The Court further held that the filing of the complaint with the Office of the President, an entity with no constitutional authority to review or discipline members of the Judiciary, was a grossly improper act. It underscored the principle of judicial independence, stating that no other department of government may pass upon or declare the judgments of the Supreme Court as “unjust.” Atty. Castellano’s claim that his actions were protected as “constructive criticism” was rejected, as his arrogant insistence that the Justices had no jurisdiction to discipline him revealed a lack of good faith. His actions vilified the Court and impaired its authority. Consequently, Atty. Castellano was found guilty of contempt and improper conduct, fined, suspended from the practice of law for six months, and warned that a repetition would be dealt with more severely.