In Re: Wenceslao Laureta (1987) Petitioners: Eva Maravilla Ilustre and Atty. Wenceslao Laureta Respondents: N/A Determining whether or not Ilustre and Laureta should be held in contempt for their remarks on the Supreme Court SUMMARY: Eva Maravilla Ilustre, in her fourth case before the Supreme Court, has been held in contempt due to the letters she sent to individual Justices, her efforts to disparage the SC in the media, and her complaint against them with the Tanodbayan. Atty. Wenceslao Laureta, her counsel, is judged to have committed acts unbecoming of an officer of the Court, and has been suspended indefinitely. FACTS: •
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Incriminating acts of Eva Maravilla Ilustre: wrote threatening letters to the Justices of the Supreme Court; filed an Affidavit-Complaint before the Tanodbayan that completely disregarded facts, circumstances, and legal considerations; instigated the circulation of a false headline implying graft and corruption charges against Justices Involvement of Atty. Wenceslao Laureta: likely wrote the threatening letters sent to the Justices in Ilustre’s name; likely encouraged Ilustre’s pursuit of her Affidavit-Complaint with the Tanodbayan and her disparaging remarks regarding the Justices in her letters and comments to the media; was responsible for all the acts of his clients
ISSUE/S: •
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WoN the Justices of the First Division acted in bad faith o NO. (Ratio: Ilustre has lost three times in court, and by virtue of res judicata, the Escolin Decision and the Javellana Resolution, which bar her from acquiring Maravilla’s properties, serve as final judgment of the case.) o SC gave ample time and consideration to her petitions, but ultimately held that they had no merit (as stated in their Banc Decision) o Justice Yap clarified that he was not aware that his former partner Atty. Sedfrey Ordoñez was the counsel for the respondents, and inhibited himself immediately upon finding out o Court is not duty bound to issue signed Decisions all the time, if it deems it unnecessary WoN Ilustre’s and Laureta’s actions violate the principle of separation of powers o YES. (Ratio: In their persistence to overturn detrimental decisions, their threats of “exposing” the supposed corruption of the SC to the media, and their unfounded complaint to the Tanodbayan, Ilustre and Laureta attempted to subject the judiciary to the executive, which is unjustifiable under separation of powers.) o Independence of the judiciary is the indispensable means for enforcing the supremacy of the Constitution
o
Reciprocity: The decisions of the SC, whether en banc or division, are as credible as the enrolled bills of the legislature, and therefore beyond investigation or inquiry; applicable also the the executive
NOTES: Timeline of Events 1964 Fernandez et al. vs. Maravilla (L-18799) Mar. 2, 1971 GR No. L-23225 • Ilustre’s first case with the SC • Maravilla will ordered probated • Followed by 2 Motions for Intervention Mar. 12, 1987 “Escolin Decision,” Heirs of Pastor Maravilla et al. vs. Hon. Ernesto S. Tengco, et al. (CA-GR No. 05394) • Ilustre failed to show right to property or interest; ruled to be legally and completely excluded from Digna Maravilla’s will Nov. 9, 1977 GR No. L-46155 • Ilustre’s 2nd case with the SC • Affirmed the Escolin Decision Feb. 29, 1979 “Macandog Decision,” Civil Case No. X-404, Court of First Instance (Negros Occidental) • Filed after death of Maravilla’s husband (her original heir), against his heirs, for partition of the properties • Ordered properties back to trunk of origin; ordered damages to be paid to Ilustre and Laureta Jan. 21, 1982 GR No. L-58014 • Special civil action for certiorari filed by previous case’s defendants (actual heirs) • SC referred it to the Court of Appeals because it dealt with questions of fact Jan. 14, 1983 “Busran Decision,” AC-GR SP No. 13680, Court of Appeals (4th Division) • Dismissed the petition, because judgment “attained finality long ago” • Reason: had remedy of appeal, not certiorari Jan. 20, 1984 “Javellana Resolution,” CA-GR SP No. 13080, Court of Appeals (4th Division) • CA overturned its own decision after the actual heairs filed a Motion for Reconsideration • Dismissed Ilustre’s complaint in Civil Case No. X-404 and ordered Court not to take further action Oct. 22, 1984 Petition for Review filed by Ilustre • Ilustre’s 3rd Case with the SC • Denied in extended minute-resolution of 05/14/86 of the SC’s First Division • Civil Case No. X-404 barred by res judicata • Was not a signed decision, just a resolution May 14, 1986 July 9, 1986 Issuance of SC’s minute-resolutions Sept. 3, 1986 Oct. 20, 1986 Ilustre’s letters received by Justices Narvasa, Herrera, and Cruz (all Justices of the SC’s First Division)
Oct. 22, 1986 Oct. 28, 1986 Nov. 3, 1986 Dec. 16, 1986 Dec. 26, 1986 Jan. 29, 1987 Feb. 9, 1987 Mar. 12, 1987
Ilustre’s letter received by Justice Feliciano; letters marked Noted for SC evaluation (also a Justice of the SC’s First Division) “Banc Decision” of the Supreme Court • Stated that there was no need to take further action Similar letters sent to Justices Narvasa, Herrera, and Cruz Affidavit-Complaint filed by Ilustre with the Tanodbayan Tanodbayan Decision to dismiss Affidavit-Complaint SC releases Resolution asking why Ilustre should not be held in contempt Compliance-Answer by Ilustre SC holds that Ilustre should be held in contempt and Laureta is suspended indefinitely
