GR 97238; (July, 1991) (Digest)
G.R. No. 97238 ; July 15, 1991
JULIA L. TAN and JAMES L. TAN, petitioners, vs. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioners Julia L. Tan and James L. Tan, administrators of Grace Christian High School, were convicted of indirect contempt. The case originated from a dispute between the school and a group of parents over tuition fee increases and demands for representation in school governance, leading to animosity. In a related mandamus case (Civil Case No. Q-51039), Branch 79 of the Quezon City RTC issued a writ of preliminary injunction on July 1, 1987, ordering the school to enroll certain children. Subsequently, a second mandamus case (Civil Case No. Q-89-2357) was filed in Branch 88 by Vicente Luy and his daughter Vonette Luy, also petitioners in the first case. During the May 1989 enrollment, the petitioners refused to admit Vonette Luy and other students to first-year high school, arguing they had no legal duty to accept them after elementary graduation. This refusal prompted a motion for indirect contempt in Branch 79 for alleged disobedience of its 1987 injunction.
ISSUE
Whether the petitioners are guilty of indirect contempt for refusing to enroll the students, thereby defying the writ of preliminary injunction issued by Branch 79.
RULING
Yes, the petitioners are guilty of indirect contempt. The Supreme Court affirmed the Court of Appeals’ decision upholding the conviction. The legal logic is clear: a writ of preliminary injunction issued by a court of competent jurisdiction must be respected and obeyed until it is annulled or set aside by a higher court. The petitioners’ unilateral determination that the writ was invalid or inapplicable did not justify disobedience. The Court emphasized that the propriety of the injunction was a separate issue to be resolved in the main case or through appellate review, not by the litigants’ own judgment. The fact that the students had graduated from the school’s elementary department and that the injunction was merely preliminary did not excuse non-compliance. The petitioners’ duty was to comply with the court’s order to ensure the orderly administration of justice. Their defiance constituted a clear obstruction of judicial functions, warranting the penalty for indirect contempt. The Court rejected the argument that academic freedom absolutely shielded the school, noting that such freedom is not boundless and must yield to lawful court processes aimed at protecting the students’ immediate educational welfare during pending litigation.