GR L 11130; (October, 1917) (Digest)
G.R. No. L-11130, October 8, 1917
BENITO GOLDING, plaintiff-appellee, vs. HIPOLITO BALATBAT, SERAPIA BALATBAT, and ESTEFANIA BALATBAT, defendants. HIPOLITO BALATBAT, appellant.
FACTS:
Benito Golding filed a complaint in the Court of First Instance of Pampanga on October 10, 1910, alleging ownership and possession of a parcel of land. He claimed that the defendants were illegally interfering with his possession and sought a preliminary and perpetual injunction to restrain them. A preliminary injunction was issued after Golding posted a bond. The defendants were served copies of the complaint and injunction on October 27, 1910. Only Hipolito Balatbat entered an appearance on November 10, 1910. None of the defendants filed an answer, leading the court to grant a motion for default judgment on November 26, 1910. After a hearing on January 4, 1911, the court rendered judgment, issuing a perpetual injunction ordering the defendants to desist from molesting Golding’s possession.
On June 15, 1914, Golding filed an affidavit alleging that Hipolito Balatbat had violated the injunction through violent acts. Balatbat was cited to show cause why he should not be punished for contempt. He confessed to violating the injunction but justified his actions by claiming ownership of the land. The court found him guilty of contempt and imposed a fine of ₱50, with subsidiary imprisonment in case of insolvency. Balatbat appealed the contempt ruling.
ISSUE:
1. Whether the procedure followed in citing and punishing Hipolito Balatbat for contempt for violating the injunction was valid.
2. Whether the injunction itself was properly granted under the circumstances.
RULING:
The Supreme Court AFFIRMED the finding of contempt but MODIFIED the penalty.
1. On the contempt proceedings: The Court held that the procedure was regular. Balatbat had been duly notified of the injunction, and a written complaint for contempt was filed. He was given an opportunity to be heard, as required by law, and he admitted violating the injunction. His claim of ownership did not excuse disobedience of a court order. However, considering his apparent ignorance, the Court reduced the fine from ₱50 to ₱5.
The Court reiterated that injunctions must not be confused with the interdictal actions under Spanish law and should be granted cautiously, respecting the availability of other adequate legal remedies.
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