THE PEOPLE PEOPLE OF THE PHILIPPINES AL.
v.
SALV SALVADOR ALARCON, ET
Facts: As an aftermath of the decision rendered by the Court of rst
Instance of Pampanga in criminal case No. 5733, he People of the Philippines !s. "al!ador Alarcon, et al., con!icting the accused therein # e$cept cept one # of the the crim crime e of robbe obbery ry comm commit itte ted d in ban band, a denuncia denunciatory tory letter, signed signed by %uis %uis &. aruc, aruc, 'as addres addressed sed to (is )$cellency, the President of the Philippines. A copy of said letter found its 'ay to the herein respondent, *ederico &a+gahas 'ho, as columnist of the Tribune, a ne'spaper of general circulation in the Philippines, uoted the letter in an article published by him in the issue of that paper of "eptember -3, /37. 0n -/ "eptember /37, the pro!incial scal of Pampanga led 'ith the Court of *irst Instance of that pro!ince to cite *ederico &angahas for contempt. 0n the same date, the lo'er court ordered &angahas to appea appearr and sho' sho' cause cause.. &anga &angaha has s appe appear ared ed and and led led an ans'e ans'er, r, alleging, among others, others, that 1the publication publication of the letter in uestion is in line 'ith the constitutional Narrati!es 2erne 4uerrero guarantee of freedom of the press.6 Issue: hether the trial court properly cited &angahas for contempt
inasmuch as the robbery8in8band case is still pending appeal. Held: Ne'spaper publications tending to impede, obstruct, embarrass,
or in9uence the courts in administering :ustice in a pending suit or proc procee eedi ding ng cons consti titu tute tes s crim crimin inal al cont contem empt pt,, 'hic 'hich h is summ summar aril ily y punis punishab hable le by the courts. courts. he he rule rule is other other'is 'ise e after after the cause is ended ended.. It must, must, ho'e! ho'e!er, er, clearl clearly y appe appear ar that that such such publi publicat catio ions ns do impede, impede, interfer interfere e 'ith, 'ith, and embarr embarrass ass the administ administrati ration on of :ustice :ustice before the author of the publications should be held for contempt. hat is thus sought to be shielded against the in9uence of ne'spaper comments is the all8important duty of the court to administer administer :ustice in the decision of a pending case. Contem Contempt pt of cour courtt is in the the natur nature e of a crimi criminal nal o;ense o;ense 2%ee 2%ee Phil., 5>?, and in considering the probable e;ects of the article alleged to be contemptuous, e!ery fair and reason reasonable able infere inference nce consisten consistentt 'ith the theory theory of defendan defendant@s t@s innocence 'ill be indulged 2"tate v . Ne' &e$ican Printing Co., -5 N. &., -, 77 p. 75, and 'here a reasonable doubt in fact or in la' e$ists as to the guilt of one of constructi!e contempt for interfering 'ith the due administration of :ustice the doubt must be resol!ed in his fa!or, and he must be acuitted.