GR L 278; (May, 1946) (Digest)
G.R. No. L-2781; May 4, 1946
Haydee Herras Teehankee vs. Director of Prisons, et al. In re Antonio Quirino, respondent.
FACTS
On February 16, 1946, the Supreme Court, by a six-to-five resolution, directed the release on bail of political detainee Haydee Herras Teehankee, reversing a previous order of the Fifth Division of the People’s Court which had denied her petition for bail. The Supreme Court’s resolution announced the majority’s intention to later promulgate a more extended written decision, with dissenting members reserving their right to deliver a written opinion. Three days later, on February 19, 1946, Judge Antonio Quirino, a member of the said People’s Court division, made statements in the presence of newspaper reporters, which were subsequently published. He criticized the Supreme Court for allegedly “committing its biggest blunder,” “robbing” the People’s Court of its “inherent power,” lacking “intellectual leadership” and having only “mere sentimental leadership.” He further stated the case was decided “by quantitative voting, not qualitative,” and branded some Supreme Court members as “intellectually dishonest.” The Supreme Court, acting on its own motion, required Judge Quirino to show cause why he should not be punished for contempt.
ISSUE
Whether Judge Antonio Quirino’s public statements criticizing the Supreme Court’s resolution in a pending case constitute contempt of court.
RULING
Yes, Judge Quirino’s statements constituted criminal contempt. The Supreme Court ruled that the Teehankee case was still pending at the time of his comments because the Court had not yet promulgated its extended decision and dissenting opinions as announced, and the matter was still open to a motion for reconsideration. A cause remains pending as long as there is something for the court to do which may be embarrassed, impeded, or obstructed by the publication. The respondent’s criticism, using intemperate language, tended to obstruct and embarrass the Supreme Court in the performance of its judicial functions. It placed the Court in a position where the subsequent exposition of its views in the full-dress opinion could be misconstrued by the public as a reaction to his criticism. His defenses—that he believed the case had terminated, that the resolution was void, that he was provoked by a dissenting opinion in a prior case, and that he had no intention to commit contempt—were all rejected. The Court emphasized the necessity of protecting the administration of justice from outside interference, while also acknowledging the constitutional guaranty of free speech, which must not be confused with license. Considering the circumstances and that Judge Quirino was a recent appointee, the Court, adopting a corrective rather than retaliatory approach, reprimanded him with a warning that a repetition would be dealt with drastically.
