G.R. Nos. L-79690-707 and L-80578, October 7, 1988
ENRIQUE A. ZALDIVAR, petitioner, vs. THE HONORABLE SANDIGANBAYAN and HONORABLE RAUL M. GONZALEZ, respondents.

FACTS

Petitioner Enrique Zaldivar was a defendant in graft cases before the Sandiganbayan, filed by the Office of the Tanodbayan headed by respondent Raul Gonzalez. Zaldivar filed two petitions (G.R. Nos. 79690-707 and 80578) before the Supreme Court, arguing that under the 1987 Constitution , the Tanodbayan (Ombudsman) no longer had the independent authority to investigate and prosecute graft cases. The Court issued temporary restraining orders (TROs) in both cases, directing the Sandiganbayan and Gonzalez to cease proceedings. Despite the TRO in G.R. No. 80578, Gonzalez caused the filing of a new information (Criminal Case No. 12570) and an arrest order against Zaldivar, prompting the Court to issue a supplemental TRO.
Subsequently, Zaldivar filed a motion to cite Gonzalez in contempt for violating the TRO. The Court also required Gonzalez to show cause why he should not be punished for contempt for making public statements attacking the Court’s integrity. Gonzalez, in his comments and speeches, accused the Court of issuing TROs to protect the powerful, described the Court as a “haven of corruption,” and claimed some Justices were pressured by friends, thereby exhibiting disrespect and attempting to undermine public confidence in the judiciary.

ISSUE

Whether respondent Raul Gonzalez is guilty of contempt of court for: (1) violating the Supreme Court’s temporary restraining orders; and (2) making public statements that constitute improper conduct as a lawyer and officer of the court, impairing public respect for the judiciary.

RULING

Yes, respondent Gonzalez is guilty of contempt on both grounds. First, his act of causing the filing of Criminal Case No. 12570 and the procurement of an arrest warrant against Zaldivar constituted a clear defiance of the Court’s lawful order (the TRO), which is a direct contempt that undermines judicial authority and the orderly administration of justice. Disobedience to a court order is punishable as contempt to preserve the court’s effectiveness and prevent obstruction of justice.
Second, his public statements, made as a lawyer and a Special Prosecutor, transcended the bounds of legitimate criticism and constituted scurrilous attacks on the integrity of the Supreme Court. The legal logic is grounded in the special responsibility of lawyers, as officers of the court, to uphold the dignity and authority of the judiciary. While lawyers enjoy free speech, their right is tempered by their ethical duty to avoid statements that would erode public confidence in the courts. Gonzalez’s allegations of corruption, partiality, and improper motives were not fair criticism but baseless attacks meant to scandalize the Court and influence its proceedings. Such conduct impairs the administration of justice and warrants disciplinary action. The Court, exercising its inherent power to punish contempt and regulate the conduct of lawyers, found Gonzalez guilty and imposed appropriate sanctions to vindicate judicial authority and maintain public trust in the legal system.