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KHALYXTO PEREZ MAGLASANG v. PEOPLE

FACTS:

On June 22, 1989, a petition for certiorari entitled "Khalyxto Perez Maglasang vs. People of the Philippines, Presiding Judge, Ernesto B. Templado (San Carlos City Court) Negros Occidental," was filed with the Court. However, the petition was dismissed on July 26, 1989, due to non-compliance with the requirements of Circular No. 1-88, including non-payment of legal fees and non-attachment of duplicate originals or certified true copies of the questioned decision and orders.

On September 9, 1989, Atty. Marceliano L. Castellano, as counsel of petitioner, filed a motion for reconsideration of the dismissal. This time, they complied with the payment of legal fees and submitted a duplicate copy of the respondent judge's decision. However, the motion did not include the duplicate originals or certified true copies of the assailed orders. The court denied the motion for reconsideration in a Resolution dated October 18, 1989.

On January 22, 1990, the Court received a copy of a complaint dated December 19, 1989, filed with the Office of the President of the Philippines. The complaint accused the five Justices of the Court's Second Division of biases, ignorance of the law, and knowingly rendering unjust judgments or resolutions. The complaint was signed by Atty. Castellano "for the complainant" with the conformity of one Calixto B. Maglasang, allegedly the father of the accused-complainant Khalyxto. The Court found the complaint to contain strong and intemperate language and determined that it was improperly filed, as the Office of the President has no jurisdiction to discipline or remove Supreme Court Justices.

As a result, Atty. Castellano was required to show cause why he should not be punished for contempt or administratively dealt with for improper conduct. He filed an "Opposition" claiming that the complaint was constructive criticism and disputed the Court's authority and jurisdiction to issue the show cause order. Atty. Castellano further made several statements in his opposition, expressing his belief in the biases and ignorance of the Justices and accusing them of sabotaging the Aquino Administration and robbing the Filipino people of genuine justice.

ISSUES:

  1. Whether Atty. Castellano should be punished for contempt or administratively dealt with for improper conduct.

  2. Whether the Court has jurisdiction over Atty. Castellano's actions.

RULING:

  1. Yes. The Court finds that Atty. Castellano's statements in his complaint and "Opposition" constitute contemptuous language and improper conduct. The use of strong and intemperate language and the filing of the complaint with the Office of the President, which lacks jurisdiction over the discipline or removal of Supreme Court Justices, demonstrate Atty. Castellano's disrespect towards the Court.

  2. Yes. The Court asserts its jurisdiction over Atty. Castellano's actions as he is subject to the disciplinary authority of the Court as a member of the legal profession.

PRINCIPLES:

  • The use of strong and intemperate language and the filing of complaints with improper authorities may be considered contemptuous and improper conduct.

  • Supreme Court Justices have disciplinary authority over lawyers and can subject them to sanctions for disrespectful or improper behavior.

  • Lawyers have a duty of respect and responsibility towards the Court and should conduct themselves in a manner consistent with the principles of the legal profession.