G.R. No. L-39115 May 26, 1975
In the Matter of the Petition for Habeas Corpus. SEGIFREDO L. ACLARACION, petitioner, vs. HON. MAGNO S. GATMAITAN, HON. JOSE N. LEUTERIO, COLONEL RUPERTO B. ACLE, Chief of Police, and Lieutenant FRANCISCO CRUZ, Warden, Makati, Rizal, respondents.

FACTS

Segifredo L. Aclaracion, a former temporary stenographer for the Court of First Instance, was ordered by the Court of Appeals to transcribe his stenographic notes in appealed cases after his employment had ended. Upon his failure to comply, he was declared in contempt. Justices of the Court of Appeals issued orders for his arrest and detention until he submitted the transcripts. Aclaracion was subsequently arrested and jailed in June 1974. He filed a petition for habeas corpus, arguing that compelling him to transcribe the notes after his service constituted involuntary servitude prohibited by the Constitution, especially as he was no longer a court employee and received no compensation for the task.
During the proceedings, the Third Division of the Court of Appeals ordered his release in August 1974, and he transcribed the notes for one case. However, he remained detained due to a separate order from another division. The Supreme Court then ordered his provisional release on the condition he complete the remaining transcription within twenty days at his new office in the Insurance Commission, which he did. The habeas corpus petition thus became moot due to his release, but the core legal issue regarding his obligation to transcribe remained for resolution.

ISSUE

Whether a court may compel a former stenographer to transcribe stenographic notes taken during his prior employment, and whether such compulsion constitutes involuntary servitude.

RULING

The Supreme Court ruled that an appellate court possesses the inherent power to compel a former court stenographer to transcribe his notes. This power is ancillary to the court’s appellate jurisdiction and is essential for the due administration of justice. The obligation to transcribe is not extinguished by the termination of the stenographer’s employment. The provision in the Rules of Court directing stenographers to prepare transcripts applies even to those no longer in the judiciary.
The Court rejected the claim of involuntary servitude. The traditional sanction for non-compliance is contempt of court, including imprisonment until the order is obeyed, as provided by the Rules. Furthermore, administrative sanctions, such as withholding clearances or promotions, are also recognized. In Aclaracion’s specific case, he transcribed the notes while receiving his salary as an employee of the Insurance Commission, as arrangements were made for him to do the work during official time. Therefore, the constitutional prohibition was not violated. The habeas corpus aspect was dismissed as moot, and his request to be relieved from transcribing notes in other pending cases was denied.