1. HALILI V.

CIR
Facts:
This case stemmed from a dispute regarding claims for overtime of more than
500 bus drivers and conductors of Halilia Transit. While the case was before the
Court of Industrial Relations, the union of the worers and the emplo!er e"ecuted
an agreement whereb! Halili Transit bound itself to deliver a parcel of land and
#$5 to the %nion, as full settlement. &o a deed of conve!ance was e"ecuted
transferring the land to the union, in trust for the members therein.
The union, through 'tt!. #ineda (led an urgent motion with the )inistr! of *abor
re+uesting for the authorit! to sell the land. )otion was granted but the bu!er
was hesitant to purchase the land because there was a law that re+uires an order
from a court as authorit! to sell properties in trust. &o 'tt!. #ineda (led a motion
with the &C re+uesting authorit! to sell. The &C merel! noted the motion in a
resolution. ,evertheless, 'tt!. #ineda (led and was granted an authorit! to sell b!
the labor arbiter. &o the sale was consummated resulting in the e"ecution of an
escrow agreement wherein the purchase price was deposited with )anila -an.
The amounts due the claimants were eventuall! released. This included attorne!.s
fees released to 'tt!. #ineda, and union e"penses released to the union.
,ow, 'tt!. /spinas, alleged original counsel for the union (led a motion for a
temporar! mandator! restraining order to re+uire both 'tt!. #ineda and the union
to deposit the amounts received b! them with the ,*RC. )anila -an was
impleaded. Thereafter, the &C issued the temporar! mandator! restraining order.
*ater on, the &C also declared the decision of the labor arbiter to grant the
authorit! to sell null and void. ' da! before the said declaration, 'tt!. /spinas (led
a motion to cite 'tt!. #ineda, Capuno 0acting administrator of the union1, and
)anila ban in contempt for non2compliance with the restraining order.
'tt!. #ineda, Capuno, and )anila -an (led a motion stating that the! had
alread! transmitted the mone! to the ,*RC, thereb! rendering the motion to cite
them in contempt moot and academic. 'pparentl!, the amounts delivered to the
,*RC were incomplete. &o 'tt!. /spinas, in representation of the worers involved,
(led a comment reiterating their plea to declare the 3 parties in contempt.
Issue:
W4, 'tt!. #ineda, Capuno, and )anila -an should be cited for contempt5
Held and Ratio:
'tt!. #ineda should be cited for indirect contempt under paragraphs 0b1, 0c1 and
0d1 of &ection 3, Rule 67, R8C.
)anila -an substantiall! complied with the temporar! mandator! restraining
order, hence cannot be cited for contempt.
Contempt against Capuno was withdrawn.
Doctrines:
Contempt of court 9 de(ance of the authorit!, :ustice or dignit! of the court which
signi(es not onl! a willful disregard or disobedience to the court.s orders, but such
conduct as tends to bring the authorit! of the court and the administration of law
into disrepute or in some manner impede the due administration of :ustice.
Power to punish for contempt is inherent in all courts. It is essential to the
preservation of order in :udicial proceedings and to the enforcement of :udgments,
orders, and mandates of the court, and conse+uentl!, to the due administration of
:ustice.
Reason for this is to guarantee the stabilit! of the :udicial institution.
Twofold aspect
071 #roper punishment for the disrespect to the court or its order; and
0$1 To compel the guilt! part!.s performance of some act or dut! re+uired of
him b! the court.
Civil Contempt
<ailure to do something ordered to be done b! a court or a :udge for the
bene(t of the opposing part! therein.
Where punishment is b! (ne directed to be paid to a part! in the nature of
damages, or b! imprisonment as a coercive measure to enforce the
performance of some act for the bene(t of the part! or in aid of the (nal
:udgment or decree rendered in his behalf
The contempt :udgment will, if made before the (nal decree, be treated as
in the nature of an interlocutor! order, or, if made after, as remedial in
nature, and ma! be reviewed onl! on appeal from the (nal decree, or in
such other appropriate mode.
Criminal contempt
Conduct directed against the authorit! and dignit! of the court or of a
:udge, as in unlawfull! assailing or discrediting the authorit! or dignit! of
the court or :udge, or in doing a dul! forbidden act.
Where the punishment imposed, whether against a part! to a suit or a
stranger, is wholl! or primaril! to protect or vindicate the dignit! and
power of the court, either b! (n pa!able to the government or b!
imprisonment, or both, it is deemed a :udgment in a criminal case.
The +uestion of whether the contempt committed is civil or criminal does not
a=ect the :urisdiction or the power of a court to punish the same.