GR L 35333; (July, 1982) (Digest)
G.R. No. L-35333. July 20, 1982.
Felix M. Sulit, petitioner, vs. Honorable Joel P. Tiangco, Judge, Circuit Criminal Court of Batangas, and Jose Aquino, Chief of Police of Batangas City, respondents.
FACTS
Petitioner Felix M. Sulit, a lawyer and private prosecutor, was summarily adjudged guilty of direct contempt by respondent Judge Joel P. Tiangco and sentenced to ten days imprisonment. The order cited Sulit’s use of “insolent, disrespectful, and contemptuous” language during a court session on July 27, which allegedly compelled the judge to suspend proceedings. Sulit filed this habeas corpus petition, contending the order lacked legal basis. He argued the act, if any, was not direct contempt as the written order was issued a day later on July 28, and he denied being disrespectful. He also noted he had separately been charged with indirect contempt earlier that same day for comments on a radio broadcast.
ISSUE
Whether the writ of habeas corpus should be granted on the ground that the order for direct contempt was issued without jurisdiction or legal basis.
RULING
The Supreme Court dismissed the petition, upholding the validity of the contempt order but finding the punishment served sufficient. The Court ruled the order was not vitiated by jurisdictional infirmity. It reiterated the doctrine that in cases of contempt in the presence of the court (in facie curiae), the judge may summarily punish the act without a hearing, relying on their own appraisal of the contumacious conduct. The delay between the incident on July 27 and the formal written order on July 28 did not negate the character of the contempt as direct, as the respondent judge had immediately made a determination and the delay was due to administrative steps.
However, the Court found the ten-day penalty severe. Citing precedents, it emphasized the contempt power must be exercised on the preservative, not vindictive, principle to maintain public confidence in judicial impartiality. The Court noted Sulit had already been detained for five days until released on bail per its interim resolution. It held this period constituted more than adequate punishment for the direct contempt committed. Thus, while the order was legally valid, the execution of the full sentence was deemed unwarranted.