HALILI vs.

CIR

FACTS: This case stemmed from a dispute regarding claims for overtime of more than 500 bus drivers and
conductors of Halilia Transit. The Union and the employer executed an agreement whereby Halili Transit
bound itself to deliver a parcel of land to the Union, as full settlement.
The union, through Atty. Pineda filed an urgent motion with the Ministry of Labor requesting for
the authority to sell the land. Motion was granted but the buyer was hesitant to purchase the land because
there was a law that requires an order from a court as authority to sell properties in trust. So Atty. Pineda
filed a motion with the SC requesting authority to sell. The SC merely noted the motion in a resolution.
Nevertheless, Atty. Pineda filed and was granted an authority to sell by the labor arbiter. So the sale was
consummated resulting in the execution of an escrow agreement wherein the purchase price was
deposited with Manila Bank. The amounts due the claimants were eventually released. This included
attorney’s fees released to Atty. Pineda, and union expenses released to the union.
Now, Atty. Espinas, alleged original counsel for the union filed a motion for a temporary mandatory
restraining order to require both Atty. Pineda and the union to deposit the amounts received by them with
the NLRC. Manila Bank was impleaded. Thereafter, the SC issued the temporary mandatory restraining
order. Later on, the SC also declared the decision of the labor arbiter to grant the authority to sell null and
void. A day before the said declaration, Atty. Espinas filed a motion to cite Atty. Pineda, Capuno (acting
administrator of the union), and Manila bank in contempt for non-compliance with the restraining order.
Atty. Pineda, Capuno, and Manila Bank filed a motion stating that they had already transmitted the
money to the NLRC, thereby rendering the motion to cite them in contempt moot and academic.
Apparently, the amounts delivered to the NLRC were incomplete. So Atty. Espinas, in representation of the
workers involved, filed a comment reiterating their plea to declare the 3 parties in contempt.

ISSUE: Whether or not Atty. Pineda, Capuno, and Manila Bank should be cited for contempt.

RULING:
• Atty. Pineda should be cited for indirect contempt under paragraphs (b), (c) and (d) of Section
3, Rule 71, ROC.
• Manila Bank substantially complied with the temporary mandatory restraining order, hence
cannot be cited for contempt.
• Contempt against Capuno was withdrawn.

DOCTRINES:

Contempt of court – defiance of the authority, justice or dignity of the court which signifies not only a willful
disregard or disobedience to the court’s orders, but such conduct as tends to bring the authority of the
court and the administration of law into disrepute or in some manner impede the due administration of
justice.

Power to punish for contempt is inherent in all courts. It is essential to the preservation of order in judicial
proceedings and to the enforcement of judgments, orders, and mandates of the court, and consequently,
to the due administration of justice.

Reason for this is to guarantee the stability of the judicial institution.

Twofold aspect
(1) Proper punishment for the disrespect to the court or its order; and
(2) To compel the guilty party’s performance of some act or duty required of him by the court.

Civil Contempt
• Failure to do something ordered to be done by a court or a judge for the benefit of the opposing
party therein.
• Where punishment is by fine directed to be paid to a party in the nature of damages, or by
imprisonment as a coercive measure to enforce the performance of some act for the benefit
of the party or in aid of the final judgment or decree rendered in his behalf
• The contempt judgment will, if made before the final decree, be treated as in the nature of an
interlocutory order, or, if made after, as remedial in nature, and may be reviewed only on
appeal from the final decree, or in such other appropriate mode.

Criminal contempt
• Conduct directed against the authority and dignity of the court or of a judge, as in unlawfully
assailing or discrediting the authority or dignity of the court or judge, or in doing a duly
forbidden act.
• Where the punishment imposed, whether against a party to a suit or a stranger, is wholly or
primarily to protect or vindicate the dignity and power of the court, either by fin payable to the
government or by imprisonment, or both, it is deemed a judgment in a criminal case.

The question of whether the contempt committed is civil or criminal does not affect the jurisdiction or the
power of a court to punish the same.