Moday v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners sought the resolution of their Omnibus Motion for the Enforcement of Restraining Order and Contempt in connection with a petition for review concerning the expropriation of petitioners' land by respondent Municipality of Bunawan. Procedural History: On December 8, 1993, the Supreme Court issued a temporary restraining order (TRO) enjoining Judge Evangeline S. Yuipco from enforcing her decision in an eminent domain case and enjoining the Municipality of Bunawan from using and occupying buildings constructed on the subject land, and from further constructing any building thereon, effective immediately and until further orders. The Petition: Petitioner alleged that the municipal mayor continued to use the buildings on the subject land and even constructed new "blocktiendas" thereon in October 1994, submitting photographs, affidavits, and an invitation as proof. Petitioner prayed that the municipal mayor and officials be cited for contempt. Petitioner also alleged that the sheriff refused to enforce the TRO, and prayed for the designation of a law enforcement agency to enforce the restraining order by padlocking the buildings and demolishing the blocktiendas. In their opposition, the municipal mayor admitted the construction of temporary booths for a municipal project due to be demolished after October 29, 1994, but submitted no proof of demolition. The respondent also alleged that the buildings and land were used for public service and public interest, not for personal purposes.
Issue(s)
Whether the respondent Municipality of Bunawan, through its mayor, is guilty of contempt of court for disobeying the temporary restraining order issued by the Supreme Court. Whether the explanation that the use of the property was for public service is a valid defense against a charge of contempt for violating a restraining order.
Ruling
The respondent Municipality of Bunawan, Agusan Del Sur, through its incumbent Municipal Mayor, is cited for contempt and is hereby FINED in the amount of one thousand pesos (P1,000.00) with the WARNING that a repetition or continuation of the acts herein found to constitute contempt of court will be dealt with more severely. The mayor is hereby ordered to DEMOLISH the structures subject of the restraining order.
Ratio Decidendi
On whether the respondent Municipality of Bunawan, through its mayor, is guilty of contempt of court for disobeying the temporary restraining order issued by the Supreme Court: The respondent Municipality of Bunawan, acting through its mayor, clearly disobeyed the restraining order issued by the Court on December 8, 1993. The respondent admits having constructed temporary booths on the subject lands as well as having used the buildings thereon for public service-oriented activities. This admission directly contradicts the explicit terms of the restraining order which enjoined the municipality from using and occupying the buildings and from further constructing any building on the land. The continued use and construction, even if for temporary booths, constituted a clear violation of the Court's directive. Therefore, the elements of contempt, namely, the existence of a valid order, the respondent's knowledge of the order, and their willful disobedience of the order, are all present. On whether the explanation that the use of the property was for public service is a valid defense against a charge of contempt for violating a restraining order: The explanation given by the respondent municipality is unacceptable. The purpose for which the buildings were used is immaterial. The respondent was duty-bound to obey the injunction issued by this Court. The TRO was explicit in its language, and violating its purpose and language is patently contemptuous and merits the corresponding punishment. The Court's orders must be respected and obeyed regardless of the perceived justification or the nature of the activities conducted on the property. The mandate of the Supreme Court, when issued, is supreme and must be complied with in its entirety. To allow such explanations would undermine the authority of the Court and render its orders ineffective.
Main Doctrine
A municipality, through its mayor, is duty-bound to obey a temporary restraining order issued by the Supreme Court, and its explanation that the use of the property was for public service is immaterial to the charge of contempt for violating the order.