In Re: Laureta and Maravilla (148 SCRA 382) – 1987
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 1st 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 complaint 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.
Eva Maravilla-Ilustre wrote a letter to the Justices of the First Division of the Supreme Court
alleging that the dismissal of her case via a minute resolution was promulgated unjustly and in
violation of the legal and judicial ethics. In her letter, she threatened that she will hold a press
conference regarding the issue and requested that the judges disclose the extent of their
paricipation in the promulgation of the minute resolution. She also claims that Justice Yap of the
first division was previously the law partner of Atty. Ordonez, then counsel of the other party,
and now the Solicitor General.
The Supreme Court, acting on the letter of Ilustre, explained that when the resolution was
issued, Justice Abad was the presiding justice and Justice Yap had no knowledge of the fact
that Atty. Ordonez was the counsel for the opponent and that Justice Yap later on inhibited
himself from the case.
Ilustre then filed a criminal complaint against the Justices before the Tanodbayan for knowingly
rendering an unjust resolution and a complaint charging Justice Yap and Atty. Ordonez of using
their influence in rendering the said resolution.
Atty. Wenceslao Laureta, counsel of Ilustre, allegedly circulated these complaints to the press.
In particular, the headline in the Daily Express read “ Ordonez, 8 Justices Face Graft Charges”
making it appear that the Justices were charged with Graft and Corruption.
The Tanodbayan dismissed the compliant and subsequently, the Supreme Court charged Atty
Laureta and Eva Ilustre and found them guilty of Contempt. Atty. Laureta claims that the order
of suspension issued without hearing was violative of his constitutional right to due process of
law making said order null and void while Ilustre claims that her constitutional right to due
process was likewise violated for she should have been given every opportunity to present her
side since contempt proceedings are in the nature of a criminal proceeding.
RATIO DECIDENDI:
The fundamental principle of separation of powers and checks and balances under a republican
form of government [means] that the three co-equal branches of government, the executive,
legislative and judicial, are each supreme and independent within the limits of its own sphere.
Neither one can interfere with the performance of the duties of the other. Our Constitution "as 'a
definition of the powers of government' placed upon the judiciary the great burden of
'determining the nature, scope and extent of such powers' and 'when the judiciary mediates to
allocate constitutional boundaries, it does not assert any superiority over the other departments
.. but only asserts the solemn and sacred obligation entrusted to it by the Constitution to
determine conflicting claims of authority under the Constitution and to establish for the parties in
an actual controversy the rights which the instrument secures and guarantees to them.'"
To subject to the threat and ordeal of investigation and prosecution, a judge, more so a member
of the Supreme Court for official acts done by him in good faith and in the regular exercise of
official duty and judicial functions is to subvert and undermine that very independence of the
judiciary and subordinate the judiciary to the executive.
Decisions of the Supreme Court are beyond investigation or inquiry
Resolutions of the Supreme Court as a collegiate court, whether en banc or division, speak for
themselves and are entitled to full faith and credence and are beyond investigation or inquiry
under the same principle of conclusiveness of enrolled bills of the legislature.
Dissatisfied litigants and/or their counsels cannot without violating the separation of powers
relitigate in another forum the final judgment of this Court on legal issues submitted by them for
final determination to and by the Supreme Court and which fall within the judicial power to
determine and adjudicate exclusively vested by the Constitution in the Supreme Court and in
such inferior courts as may be established by law.
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 1st Division, that it was
railroaded with such hurry beyond the limits of legal and judicial ethics.
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 opponent’s
counsel. It was also made clear that Justice Yap eventually inhibited himself from the case.
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.
The Tanodbayan dismissed the complaint.
In short, 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.