In Re: Laureta

Facts:

Maravilla Illustre wrote to the justices of the SC, complaining about the dismissal of the her case (a land dispute involving large estate) by a minute-resolution. Illustre claims that it was an unjust resolution deliberately and knowingly promulgated by the 1^st Division, that it was railroaded with such hurry beyond the limits of legal and judicial ethics.

Illustre also threatened in her letter that, “there is nothing final in this world. This case is far from finished by a long shot.” She threatened that she would call for a press conference.

Illustre’s letter basically attacks the participation of Justice Pedro Yap in the first division. It was established that Justice Yap was previously a law partner of Atty. Ordonez, now the Solgen and counsel for the opponents.

The letters were referred to the SC en banc. The SC clarified that when the minute-resolution was issued, the presiding justice then was not Justice Yap but Justice Abad Santos (who was about to retire), and that Justice Yap was not aware that Atty Ordonez was the opponents counsel. It was also made clear that Justice Yap eventually inhibited himself from the case.

Still, Illustre wrote letters to the other justices (Narvasa, Herrera, Cruz), again with more threats to “expose the kind of judicial performance readily constituting travesty of justice.”

True to her threats, Illustre later filed a criminal complaint before the Tanodbayan, charging the Justices with knowingly rendering an unjust Minute Resolution. Justice Yap and Solgen Ordonez were also charged of using their influence in the First Division in rendering said Minute Resolution.

Atty LAURETA was the counsel of Illustre. He circulate copies of the complain to the press, without any copy furnished the Court, nor the Justices charged. It was made to appear that the Justices were charged with graft and corruption.

The Tanodbayan dismissed the complaint. Now, the SC is charging them with contempt.  They claim that the letters were private communication, and that they did not intend to dishonor the court.

Issue:

Whether or not the privacy of communication was violated.

Held:

The letters formed part of the judicial record and are a matter of concern for the entire court.

There is no vindictive reprisal involved here. The Court’s authority and duty under the premises is unmistakable. It must act to preserve its honor and dignity from the scurrilous attacks of an irate lawyer, mouthed by his client, and to safeguard the morals and ethics of the legal profession.

We’re not convinced that Atty Laureta had nothing to do with Ilustre’s letters, nor with the complaint filed with the tanodbayan. Atty Laureta repeated disparaging remarks such as “undue influence”, powerful influence” in his pleadings. This was bolstered by the report that Laureta distributed copies of the complaint to the newspaper companies in envelopes bearing his name. He was also heard over the radio. Lastly, as Illustre’s lawyer, he had control of the proceedings.

SC resolutions are beyond investigation from other departments of the government because of separation of powers. The correctness of the SC decisions are conclusive upon other branches of government.