G.R. No. L-49299. April 15, 1988.
NORA CONTADO, ADELINA RAZON and NERA TIZON, petitioners, vs. RUFILO L. TAN, et al., respondents.

FACTS

Petitioners Nora Contado, Adelina Razon, and Nera Tizon filed this petition for habeas corpus on November 20, 1978, seeking the production of their spouses Crispo Contado, Cesar Razon, and Jimmy Tizon. They alleged that on September 13, 1978, their spouses were arrested, detained, and subjected to severe torture by the respondents, including then Mayor Rufilo L. Tan of Llorente, Eastern Samar, and members of the local Integrated National Police and Philippine Constabulary. The petitioners detailed horrific abuse, including beatings, cigarette burns, forced ingestion of urine, and starvation. They further alleged that on September 18, 1978, the detainees were clandestinely taken from the municipal jail via ambulance to an unknown location in Can-avid or Oras, Eastern Samar, escorted by PC soldiers, leading to grave fears they had been “liquidated.”
Upon filing, the Court issued the writ. In their returns, respondents uniformly claimed the three men had been released on the evening of their arrest, September 13, 1978, at 8:00 P.M., rendering the petition moot. Petitioners countered with affidavits from witnesses who saw one detainee in jail on September 14 and 15, and noted that even a respondent official had stated he recommended release only on September 15. They argued that if their husbands had been truly released, they would have returned home.

ISSUE

Whether the respondents are guilty of contempt of court for filing false returns in the habeas corpus proceedings regarding the release and whereabouts of the detainees.

RULING

Yes, the respondents are guilty of contempt. The Court found their claim of release on September 13, 1978, to be a deliberate falsehood. The writ of habeas corpus commands the production of the detainee’s body. The respondents’ uniform but fabricated returns, asserting a release that never occurred, constituted a direct obstruction of justice and a gross abuse of the court’s process. This falsehood prevented the Court from effectively discharging its duty to inquire into the legality of the detention and the detainees’ fate.
The legal logic is rooted in the court’s inherent power to punish for contempt when its authority is defied and its processes are abused. The filing of a perjured return in a habeas corpus case is a particularly serious contempt because it subverts a fundamental remedy designed to protect liberty. The Court emphasized that its contempt power is exercised on a corrective, not vindictive, principle. While the Court imposed a fine of P1,000.00 on each respondent, it notably referred the case to the Secretary of Justice for criminal prosecution for perjury and other charges, including murder, as subsequent evidence (including a related Sandiganbayan decision) indicated the three detainees had been killed. Thus, the contempt ruling served to uphold judicial integrity against official deception in a case involving enforced disappearances.