Marantan v. Diokno
REITERATIONFacts
The Antecedents: Petitioner P/Supt. Hansel M. Marantan was the respondent in G.R. No. 199462, a petition filed by respondent Monique Cu-Unjieng La’O and others, seeking to annul the Ombudsman's resolution downgrading murder charges to homicide in connection with the November 7, 2005 incident where Anton Cu-Unjieng (son of respondent La’O) and others were killed by police officers (Ortigas incident). Subsequently, on January 6, 2013, Marantan was the ground commander in a police-military operation in Atimonan, Quezon, which resulted in the death of thirteen men (Atimonan incident). Marantan alleged that respondents La’O and her counsel, Atty. Jose Manuel Diokno, along with Ernesto Manzano, organized a televised/radio broadcasted press conference, where they made allegedly malicious, intemperate, and unreasonable comments regarding the Court's handling of G.R. No. 199462 and the merits of the criminal cases before the RTC, branding Marantan and his co-accused as guilty of murder in the Ortigas incident. These statements were featured in a news program. Procedural History: The present case is a petition filed by Marantan to cite respondents Atty. Diokno and La’O in contempt of court for allegedly violating the sub judice rule. The Petition: Marantan submits that the respondents violated the sub judice rule, making them liable for indirect contempt under Section 3(d) of Rule 71 of the Rules of Court, for their contemptuous statements and improper conduct tending directly or indirectly to impede, obstruct, or degrade the administration of justice. He argued that their pronouncements commented on the Court's inaction and the merits of the criminal cases, prematurely concluding guilt, and that the press conference aimed to influence the Court's decision and the RTC's outcome by drawing a parallelism between the Ortigas and Atimonan incidents.
Issue(s)
Whether the statements made by respondents Atty. Jose Manuel Diokno and Monique Cu-Unjieng La’O during a press conference constitute indirect contempt of court for violating the sub judice rule. Whether the said statements tended to impede, obstruct, or degrade the administration of justice.
Ruling
The petition is DISMISSED.
Ratio Decidendi
On the issue of indirect contempt and the sub judice rule: The Court held that the sub judice rule restricts comments and disclosures pertaining to judicial proceedings to avoid prejudging issues, influencing the court, or obstructing justice. A violation can lead to indirect contempt under Sec. 3(d), Rule 71 of the Rules of Court. However, the proceedings for indirect contempt are criminal in nature, requiring clear evidence of intent to commit contempt. For a comment to be considered contemptuous, it must demonstrably impede, interfere with, and embarrass the administration of justice. The rationale behind the sub judice rule is to protect the court's duty to administer justice impartially, free from extraneous influences, bias, prejudice, or sympathies. The Court reiterated that the "clear and present danger" rule applies, meaning the evil consequence must be extremely serious and the degree of imminence extremely high before an utterance can be punished. There must be an imminent, not merely a likely, threat to the administration of justice. On the issue of whether the statements tended to impede, obstruct, or degrade the administration of justice: The Court found that the respondents' comments regarding the merits of the case were merely a reiteration of their position in G.R. No. 199462, which sought to upgrade the charges from homicide to murder. The Court detected no malice on the face of these statements, as the mere restatement of an argument in a petition does not tend to influence the Court. Regarding the conduct of the Court, the comments were interpreted as simply stating that their petition had not yet been resolved, without any express or implied complaint of inordinate delay or any attack on the dignity of the Court. The Court concluded that the respondents' comments did not pose a serious and imminent threat to the administration of justice, and no criminal intent to impede, obstruct, or degrade the administration of justice could be inferred. Therefore, the necessity to resort to the power of contempt was wanting, as freedom of public comment should, in borderline instances, weigh heavily against a possible tendency to influence pending cases.
Main Doctrine
Statements made during a press conference, even if concerning pending judicial proceedings, do not constitute indirect contempt under the sub judice rule if they do not pose a clear and present danger of impeding, obstructing, or degrading the administration of justice, and if no criminal intent to do so can be inferred.