People vs. Alarcon, et al. G.R. No. 46551 December 12, 1939

G.R. No. 46551 December 12, 1939

THE PEOPLE OF THE PHILIPPINES, plaintiff-appelle,
vs. SALVADOR ALARCON, ET AL., accused.
FEDERICO MANGAHAS, respondent-appellant.

NATURE: RULE 45 APPEAL BY CERTIORARI (QUESTION OF LAW)

KEYWORD: FREEDOM OF THE PRESS

SUMMARY: Newspaper publications tending to impede, obstruct, embarrass, or influence the courts in administering justice in a pending suit or proceeding constitutes criminal contempt, which is summarily punishable by the courts. The rule is otherwise after the cause is ended.

FACTS: As an aftermath of the decision rendered by the Court of First Instance of Pampanga in Criminal Case No. 5733, The People of the Philippines vs. Salvador Alarcon, et al., convicting the accused therein except one of the crime of robbery committed in band, a denunciatory letter, signed by Luis M. Taruc, was addressed to His Excellency, the President of the Philippines. A copy of said letter found its way to the herein respondent, Federico Mangahas who, as columnist of the Tribune, a newspaper of general circulation in the Philippines, quoted the letter in an article published by him in the issue of that paper of September 23, 1937.

0n September 29, 1937, the provincial fiscal of Pampanga filed with the Court of First Instance of that province to cite Federico Mangahas for contempt. 0n the same date, the lower court ordered Mangahas to appear and show cause. Mangahas appeared and filed an answer, alleging, among others, that "the publication of the letter in question is in line with the constitutional guarantee of freedom of the press.

ISSUE: Whether the trial court properly cited Mangahas for contempt in as much as the robbery-in-a-band case is still pending appeal?

HELD: Newspaper publications tending to impede, obstruct, embarrass, or influence the courts in administering justice in a pending suit or proceeding constitutes criminal contempt, which is summarily punishable by the courts. The rule is otherwise after the cause is ended. It must, however, clearly appear that such publications do impede, interfere with, and embarrass the administration of justice before the author of the publications should be held for contempt. That is thus sought to be shielded against the influence of newspaper comments is the all-important duty of the court to administer justice in the decision of a pending case.

Contempt of court is in the nature of a criminal offense. (Lee Yick Hon vs Collector of Customs, 41 Phil, 548), and in considering the probable effects of the article alleged to be contemptuous, every fair and reasonable inference consistent with the theory of defendant's innocence will be indulged and where a reasonable doubt in fact or in law exists as to the guilt of one of constructive contempt for interfering with the due administration of justice the doubt must be resolved in his favor, and he must be acquitted.

RULING: The appealed order is hereby reversed, and the respondent acquitted, without pronouncement as to costs. So ordered.