OLIVIA LAUREL et. al. vs. JUDGE PABLO B.

FRANCISCO
A.M. No. RTJ-06-1992, July 6, 2010

FACTS:
This is a consolidation of several administrative cases filed by Judge Pablo Francisco against a
number of court employees of RTC Bian, Laguna which resulted after the latter wrote a letter
demanding that the former be ordered to return to his permanent post at the RTC of Sta. Cruz, Laguna.
An Order was issued by Judge Francisco finding Laurel ET. Al. guilty of Direct Contempt and
sentenced them 9 days imprisonment. The latter filed a certiorari and Prohibition before the CA
which issued a TRO against the implementation of the Order. Ca later set aside the Direct Contempt
Order for being issued by Judge Francisco with grave abuse of discretion. CA denied the appeal of
Judge Francisco.
The latter averred that such Order was not the result of a single disrespectful act, but the culmination
of a series of discourteous acts of Javier, Laurel, Ramos, and Pros. Nofuente, which impeded the
administration of justice, particularly, causing the disruption of the court proceedings. He presented
a TSN of the hearing of Sp. Proc. No. B-2433 to show that the proceedings was disturbed because of
a loud encounter between Pros. Nofuente and the employees of Br. 25.
Javier, Laurel and Ramos claimed that Judge Francisco’s accusations against them were malicious and
made to satisfy the judge’s personal grudge against them. They also accused him of falsifying the TSN
of the proceedings, alleging that Judge Francisco coerced and threatened Stenographic Reporter
Lopez to insert and add words, phrases, and situations in the said transcript to make it appear that
Pros. Nofuente disrupted court proceedings. Lopez even executed an Affidavit attesting that she was
pressured by Judge Francisco into entering the said falsities into the TSN.
Javier, Laurel, and Ramos further stated that almost all of the court personnel of the RTC of Bian,
Laguna had fallen victim to Judge Francisco’s vindictiveness. Judge Francisco became hostile to
everybody. He branded the court personnel as disrespectful, misinterpreting the latter’s smiles and
glances as making faces or laughter as insult. It was for this reason that some personnel filed a
petition with the SC requesting for Judge Francisco’s return to his original station at the RTC of Sta.
Cruz, Laguna.
ISSUE:
W/N Judge Francisco’s issuance of the Direct Contempt Order was in grave abuse of his discretion.
RULING:
Yes. As previously mentioned herein, the CA granted the Petition for Certiorari of Javier, Laurel,
Ramos, and Pros. Nofuente, and set aside Judge Francisco’s Direct Contempt Order for having been
issued in grave abuse of discretion.
Contempt of court is defined as some act or conduct which tends to interfere with the business of the
court, by a refusal to obey some lawful order of the court, or some act of disrespect to the dignity of
the court which in some way tends to interfere with or hamper the orderly proceedings of the court
and thus lessens the general efficiency of the same. It has also been described as a defiance of the
authority, justice or dignity of the court; such conduct as tends to bring the authority and
administration of the law into disrespect or to interfere with or prejudice parties litigants or their
witnesses during litigation. Simply put, it is despising of the authority, justice, or dignity of the court.