G.R. No. L-10236-48; January 31, 1958
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. EUSTACIO DE LUNA, ET AL., defendants-appellees.

FACTS

The prosecution appealed an order from the Court of First Instance of Manila dismissing multiple cases for contempt of court against the defendants-appellees (Eustacio de Luna, et al.). The amended informations alleged that on or about December 22, 1954, in Manila, each defendant, knowing they had not passed the bar examination and were not authorized to take the lawyer’s oath, and having been informed that Republic Act No. 972 (the “Bar Flunkers Act”) was unconstitutional and that the Supreme Court had denied their petitions for admission to the bar, willfully and contemptuously disobeyed the Supreme Court’s resolution. They did so by taking an oath as a lawyer before a notary public and making manifestations to that effect before the Supreme Court, performing acts that tend to impede, obstruct, or degrade the administration of justice and impair the respect and authority of the Supreme Court and all other inferior courts. The lower court granted the motion to dismiss, holding it lacked jurisdiction because the contempt was allegedly committed against the Supreme Court, not the Court of First Instance, and that the facts alleged did not constitute the crime of contempt.

ISSUE

1. Whether the Court of First Instance of Manila has jurisdiction to try and punish the defendants for the alleged contempt.
2. Whether the facts alleged in the amended informations constitute the crime of contempt of court.

RULING

1. Yes, the Court of First Instance of Manila has jurisdiction. The Supreme Court held that the lower court’s conclusion was untenable. The provision in Rule 64, Section 4, stating that contempt against a superior court may be filed with that court, is permissive and declaratory of inherent powers, not exclusive. The Supreme Court’s rule-making power does not extend to determining jurisdiction, which is vested in Congress by the Constitution. Furthermore, the amended informations alleged the acts were committed in contempt of the Supreme Court and “all other courts of the Philippines,” including the Court of First Instance of Manila. Additionally, since the penalty for contempt (a fine not exceeding P1,000 or imprisonment not exceeding six months) falls within the original jurisdiction of courts of first instance under the Revised Judiciary Act, the Court of First Instance of Manila has concurrent jurisdiction with the Supreme Court, though the court against which the contempt was committed has a preferential right to try the case.
2. Yes, the facts alleged constitute contempt of court. The acts of taking an unauthorized oath as a lawyer and notifying the Supreme Court of that act, after the Court had definitively denied their admission, constituted a willful defiance and challenge to the Supreme Court’s authority. These acts are “improper conduct tending, directly or indirectly, to impede, obstruct, or degrade the administration of justice,” in violation of Rule 64, Section 3(b). The defendants’ actions brought the court into disrespect and challenged its authority, which constitutes contempt. The lower court’s impression that contempt required actual practice of law or circulation of circulars was inaccurate; assuming to be an attorney without authority is one form of contempt, and by taking the oath and notifying the Court, the defendants had held themselves out as attorneys-at-law.
The order of dismissal was reversed, and the records were remanded to the court of origin for further proceedings.