May 3, 1976.

Jorge Royeca v Judge Animas (CFI South Cotabato)

FACTS:
Royeca filed a motion for inhibition of Animas in a pending civil case (recovery of
possession) where Royeca was the plaintiff. Animas required Royeca and his lawyer to appear
to explain why they should not be subjected to disciplinary action, they did so and apologized.
Animas found cited them in direct contempt, the sentence being 10 days imprisonment and a
fine of 200 pesos.
Royeca argues flagrant misuse of contempt power since there was nothing offensive to
the dignity of the court in his motion: Petitioner is "left with no choice but to doubt the
court... it failed to dispense justice." Further, Royeca argues that the assailed order is
characterized as character assassination: Petitioner has a "polluted and stupid mind...a self-
anointed tyrant...assumed posture of crocodile, while displaying tears, will grab any
victim without questions asked."
Animas argues he only defended himself against the false and malicious motion of
Royeca.
Royeca's counsel actually filed a motion to withdraw inhibition and apologized
beforehand for stating that "the evidence was unquestionable... the Court should have just
asked the respondent to vacate, but surprisingly, the Court suggested an amicable
settlement which was impossible."
Animas argues that he set a hearing due to the impossibility of the settlement but,
Royeca, displaying arrogance, demanded the Court to order respondent to vacate without trial.

ISSUE:
W/N contempt power was used properly.

HELD:
NO. Even if Animas was motivated by what he believed to be an appropriate response to an
attack to the court, his choice of words show resentment towards Royeca. A judge should be a
dispassionate arbiter. The contempt power should not be used to satisfy a natural inclination to
strike back at a party who has not shown respect to the court.

(People v Estenzo) Courts have the inherent power to punish for contempt. But, unless
exercised with restraint, the power lends itself to arbitrariness. Such she be exercised on
the preservative, and not on the vindictive principle. Only occasionally should the court invoke
its power to retain respect. A judge should be impartial and fair, in most cases, an
admonition or warning should suffice.
(Green v US; Justice Harlan) Where Congress has not imposed limitations on contempt power,
courts have the duty to exercise such with utmost responsibility. What started out as a very
limited and insignificant thing, has relentlessly swollen, at the hands of not unwilling
judges.

Direct contempt nullified and set aside.

Canon 4, Canons of Judicial Ethics (Essential Conduct)

a. A judge should be temperate, patient, attentive, impartial, and,
b. since he is to administer the law and apply it to the facts, he should be studious of the

principles of law, diligent in endeavoring to ascertain the facts.