G.R. No. L-20411 February 17, 1968
BARTOLOME E. SAN DIEGO, petitioner-appellee, vs. SALVADOR R. VILLAGRACIA, ET AL., respondents, ATTYS. JESUS M. NACIONGAYO, AGUSTIN T. MISOLA and PROCOPIO SANTOS, respondents-appellants.

FACTS

On November 3, 1958, Bartolome San Diego filed a certiorari petition in the Court of First Instance of Manila to annul a decision of the Iloilo Regional Office of the Department of Labor ordering him to pay death compensation. He challenged the constitutionality of Reorganization Plan 20-A, which granted regional offices jurisdiction over workmen’s compensation claims. The court issued a preliminary injunction on April 24, 1959, directing respondents Villagracia and Cabili (officials of Regional Office 5) and their agents to refrain from proceeding in the compensation case (WCC Case No. 1319). However, at the time of filing, the case had already been elevated to the Workmen’s Compensation Commission (WCC) in Manila for review. San Diego amended his petition on August 27, 1959, to include the WCC commissioners, but this was only admitted by the court on February 1, 1960. Meanwhile, the WCC proceeded, decided the case, and through its secretary, Procopio Santos, issued a writ of execution on January 22, 1960. Attorneys Jesus Naciongayo and Agustin Misola, representing the claimant, acted to implement this writ. San Diego moved to cite them and Santos for contempt for violating the injunction. The lower court found them guilty and fined them. They appealed.

ISSUE

Whether the respondents-appellants (Attys. Jesus Naciongayo, Agustin Misola, and Procopio Santos) were guilty of contempt for disobeying the writ of preliminary injunction issued by the lower court.

RULING

No. The order finding the respondents-appellants guilty of contempt is reversed and set aside, and they are absolved.
The Court held that the two requisites for contempt based on disobedience of a court order are: (1) the writ must be lawful, and (2) the disobedience must be willful. Neither requisite was present. First, the writ was not lawful. The injunction was a nullity because the lower court had no jurisdiction to issue it. Jurisdiction over workmen’s compensation claims belonged to the labor regional offices and the WCC, whose decisions were appealable to the Supreme Court, not to courts of first instance. Since Reorganization Plan 20-A had been held constitutional, the regional office and the WCC acted within their jurisdiction. A court without jurisdiction cannot issue a valid injunction. Second, the disobedience was not willful. The injunction was directed only against officials of Regional Office 5 and their agents. The WCC and its officials (including Santos) were not parties to the case when the writ was issued and the execution was carried out. Willfulness implies knowledge of the order, and one who is not a party cannot reasonably be aware of it. Furthermore, no amended injunction was issued to cover the WCC officials even after the petition was amended. Santos, in issuing the writ, was merely performing a duty enjoined by law in the absence of a valid restraining order against him.