GUILLAMON, Steffi PEOPLE VS. EUSTACIO DE LUNA, et al. G.R. Nos. L-102!-"# $a%&a'( 1, 1)*#
The defendant defendants, s, who took and failed the Bar exams, exams, were were accused accused of contemp contemptuo tuously usly disobeying the Supreme Court Resolution, obstructing or degrading the administration of justice, and disrespecting the Court by taking their oath as lawyers law yers before a notary public and making manifestations before the High Court The case was filed before the Court of !irst "nstance of #anila $C!" #anila% Howe&er, the lower court ruled that it had no jurisdiction to try the case as the contempt was not committed against it but against the Supreme Court The C!"'s decision was anchored on Rule () Section ) of the Rules of Court and Corpus Juris Secundum Secundum * The Supreme Court howe&er, &aried in opinion "t stated that the pro&isions cited are merely permissi&e permissi&e in nature, nature, and that it was merely declaratory declaratory of the inherent power power of the cour courts ts to puni punish sh thos thosee guilt guilty y of cont contem empt pt agai agains nstt it "t cont contin inue ued d by sayin saying g that that the the jurisdiction of the court to punish contempt is not exclusi&e The Supreme Court has no authority to exercise such denial #oreo&er, the allegations claimed that the defendants performed acts in contempt of the Supreme Court, as well as all other court of the +hilippines, including the C!" #anila ppellees knew that they did not pass the bar examination They were notified of the resolution of the Supreme Court denying their petition The resolution denying the petition of appellees necessarily implied a denial of the right to said oath "t also ser&ed as a prohibition of against the taking thereof -e&ertheless, appellees took the oath before a notary public, and formally ad&ised the Supreme Court that they will practice in all the courts of the +hilippines, in clear &iolation of the Resolution of the Surpreme Court By their act of taking .the oath of office and notifying the Supreme Court of the same and that they would /practice law in all courts of the +hilippines/, the appellees had presented themsel&es as such attorneys0at0law, in clear contempt of the order issued by the Court The appellees o&ertly challenged and defied the authority of the Supreme Court to decide upon the the issu issuee of admi admiss ssio ion n #ore #oreo& o&er er,, they they emba embarr rras ased ed,, hind hinder ered ed and and obst obstru ruct cted ed the the administration of justice and disrespected the courts of justice, especially the Supreme Court, 1ualified as contemptuous acts under section 2$b% Rule () of the Rules of Court
1 “Where the contempt . . . has been committed against a superior court or judge, or against an
officer appointed by it, the charge may be filed with such superior court.”