In Re: Atty. Vicente Sotto (1949)

82 Phil. 595 – Legal Ethics – Canon II; Propriety – Contempt of Court – Press Freedom

Senator Vicente Sotto, the principal author of the Press Freedom Law (Republic Act No. 53), publicly criticized the Supreme Court’s decision in In re Parazo, where a journalist was held in contempt for refusing to reveal a news source. In statements published in newspapers like the Manila Times, Sotto accused the Court of incompetence and narrow-mindedness, and suggested a legislative reorganization of the judiciary. The Supreme Court issued an order requiring Sotto to show cause why he should not be held in contempt. Despite extensions, Sotto submitted his response late and failed to appear at the scheduled hearing.

ISSUE: Can the constitutional guarantee of freedom of speech shield Sotto from contempt charges?

HELD: No. The Supreme Court found Sotto guilty of contempt. It emphasized that the judiciary possesses inherent powers to punish actions that obstruct justice or degrade its authority, independent of statutory provisions. While acknowledging the importance of free speech, the Court distinguished between permissible criticism and statements that aim to intimidate or undermine the judiciary. Sotto’s public remarks were deemed to have crossed this line. He was fined ₱1,000, with subsidiary imprisonment in case of insolvency, and was ordered to show cause why he should not be disbarred.

This case demonstrates that the courts have inherent authority to punish for contempt to maintain its dignity and ensure the unimpeded administration of justice. Freedom of speech does not protect statements that aim to intimidate the court or erode public confidence in the judicial system.

This case underscores the balance between freedom of expression and the need to uphold the integrity of the judiciary. It serves as a precedent for delineating the limits of permissible criticism of judicial decisions.

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