G.R. No. L-5059-60 January 30, 1953
The People of the Philippines, plaintiff-appellant, vs. Simeon Mendoza and Jose Dizon, defendants-appellees.

FACTS

The Provincial Fiscal of Pangasinan filed two separate informations for contempt against Simeon Mendoza and Jose Dizon. The informations charged them with violating an interlocutory order dated May 23, 1949, issued by a representative of the Department of Justice under Commonwealth Act No. 461 , as amended, in tenancy cases. The order directed them to desist from prohibiting their tenants from working on the landholdings pending investigation. The accused filed motions to dismiss, which the trial court granted in a single order. The trial court dismissed the informations on the ground that although Commonwealth Act No. 461 , as amended by Republic Act No. 44 , declares a violation of such an order punishable as contempt, the law fails to prescribe any penalty for such contempt. The court also noted the abolition of the Tenancy Law Enforcement Division and the transfer of its functions to the Court of Industrial Relations but found it unnecessary to rule on jurisdictional questions arising from this. The Solicitor General appealed, contending the lower court erred in holding no penalty was prescribed and in ruling Rule 64 of the Rules of Court inapplicable, arguing that the legislative intent was to provide an enforcement mechanism and that the cases fall under Section 580 of the Revised Administrative Code.

ISSUE

Whether the violation of an order issued by a Department of Justice representative under Commonwealth Act No. 461 , as amended, constitutes a punishable contempt, given the law’s declaration of such acts as contempt but its failure to prescribe a specific penalty.

RULING

The Supreme Court affirmed the trial court’s order dismissing the informations. The Court held that Commonwealth Act No. 461 , as amended by Republic Act No. 44 , while declaring disobedience to its orders punishable as contempt, fails to define such violation as contempt of court or to prescribe any penalty for it. The Court ruled that Rule 64 of the Rules of Court applies only to contempt committed against inferior or superior courts and does not extend to administrative officials or bodies unless the law expressly defines the contempt as contempt of court. The Court distinguished other laws (like Commonwealth Act No. 103 for the Court of Industrial Relations, Commonwealth Act No. 83 for the Securities Act, and Commonwealth Act No. 146 for the Public Service Commission) which either explicitly term violations as contempt of court or authorize summary punishment with prescribed penalties. Since Commonwealth Act No. 461 , as amended, lacks such clear provisions, the accused could not be punished. The Court found it unnecessary to address the issue of jurisdiction or the effect of the abolition of the Tenancy Law Enforcement Division.