People v. Ac-ac

G.R. No. 45551 · 1940-01-31 · J. CONCEPCION, J.: · Primary: Ethics; Secondary: Remedial
REITERATION

Facts

The Antecedents: Attorney Marcelino Lontok represented Primitivo B. Ac-ac, who was convicted in a criminal case and sentenced to imprisonment and indemnity. Ac-ac appealed to the Supreme Court, which affirmed the decision. A motion for reconsideration was denied. Procedural History: Lontok filed a motion for a new hearing, preparatory to a petition for certiorari to the Supreme Court of the United States, and simultaneously requested a stay of execution pending the certiorari petition. The Solicitor General opposed the stay, predicting denial of certiorari. The Supreme Court denied the motion for stay, and a subsequent motion for reconsideration was also denied. Ac-ac then petitioned for parole to the President, and Lontok joined this petition. The Petition: Following the denial of parole, Lontok wrote a letter to the Honorable Jorge Vargas, Secretary to the President, requesting reconsideration and insisting on the parole for his client. In this letter, Lontok stated that the Supreme Court's denial of the stay of execution was tantamount to depriving his client of his constitutional right to justice and that the Court was curtailing his client's rights and railroaded him to jail. He further opined that the President's non-intervention would be a passive sanction to an injustice committed by the Supreme Court.

Issue(s)

Whether Attorney Marcelino Lontok's letter to the Secretary of the President constitutes contempt of court.

Ruling

The Supreme Court found Attorney Marcelino Lontok guilty of contempt of court. The Court ordered that he be reprimanded, stating that his expressions could not be tolerated as they were an open contempt of the Court, and his conviction, however honest, did not justify the use of offensive language to the dignity of the Court.

Ratio Decidendi

On Issue 1: The Supreme Court held that Attorney Marcelino Lontok was guilty of contempt of court. The Court reasoned that Lontok's letter to the Secretary of the President, wherein he stated that the Supreme Court's denial of a stay of execution was "tantamount to depriving my said client his inherent right to have justice, as guaranteed by the Constitution" and that the Tribunal "stands for justice and equality is the very Tribunal which will curtail one's right and railroad my client to jail," was an open contempt of the Court. Furthermore, Lontok's opinion that the President's non-intervention would be "a passive sanction to an injustice committed by the very Tribunal whose duty it is to dispense (with) real justice" was also deemed offensive. The Court emphasized that even if Lontok's conviction of an injustice was honest, it did not justify his use of offensive language that attacked the dignity of the Court. Therefore, the Court ordered that Lontok be reprimanded for his conduct.

Main Doctrine

The Supreme Court held that Attorney Marcelino Lontok was guilty of contempt of court for his letter to the Secretary of the President, which implied that the Supreme Court had been unjust to his client. The Court found that Lontok's expressions, even if made in the honest conviction of an injustice, were offensive to the dignity of the Court and could not be tolerated. This reiterates the principle that attorneys must maintain respect for the judiciary, regardless of their personal beliefs about the outcome of a case.

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