**Facts:**
This case arose when defendants Eustacio de Luna and others, aware that they had not passed the bar examination nor were authorized to take the oath as lawyers, wilfully disobeyed the Supreme Court’s resolution. The disputed act involved taking an oath as lawyers before a notary public on December 22, 1954, defying a Supreme Court resolution dated March 18, 1954, which declined their petitions for admission to the bar based on Republic Act No. 972 (Bar Flunkers Act of 1953). The defendants had been previously informed that certain provisions of Republic Act No. 972 were unconstitutional and void.
The case proceeded to the Court of First Instance of Manila, where the defendants filed a motion to dismiss on the grounds of lack of jurisdiction and the claim that the facts did not constitute the crime of contempt. The court granted their motion, prompting the prosecution to appeal to the Supreme Court. The appeal contested the dismissal, arguing that the Court of First Instance had erroneously interpreted its jurisdiction and the definition of contempt.
**Issues:**
1. Whether the Court of First Instance of Manila held jurisdiction to try the defendants for contempt.
2. Whether the defendants’ actions constituted contempt of court.
**Court’s Decision:**
The Supreme Court reversed the order of the Court of First Instance of Manila. It clarified that the lower court indeed had jurisdiction over contempt cases, not exclusively reserved to the Supreme Court, as indicated by the inherent power of courts to punish for contempt and legislative statutes. Furthermore, the Supreme Court detailed that the defendants’ actions constituted contempt. By taking the oath as lawyers and announcing their intention to practice law across the Philippines despite explicit disqualification, the defendants directly challenged the Supreme Court’s authority and disturbed the administration of justice.
**Doctrine:**
This case reaffirmed the principle that contempt power is inherent in courts to protect their judicial authority and ensure the administration of justice. It also highlighted that jurisdiction over contempt cases can be concurrent among courts and is not exclusively held by the court directly offended. Moreover, the act of assuming the role of a lawyer without proper authorization constitutes contempt of court.
**Class Notes:**
– **Essential Elements of Contempt:** Act of disobedience or resistance to a lawful court order; improper conduct tending to impede, obstruct, or degrade the administration of justice.
– **Concurrent Jurisdiction in Contempt Cases:** Courts of First Instance and the Supreme Court have concurrent jurisdiction over contempt cases, although the court directly offended may have preferential right to try and punish the guilty party.
– **Authority and Dignity of Courts:** Actions challenging the authority of or disrespecting the court, directly or indirectly, can be punished as contempt.
**Historical Background:**
This case took place in the context of early post-war Philippines, during a period of legal and judicial reconstruction. The Bar Flunkers Act of 1953 aimed at allowing those who failed the bar exams between 1946 to 1952 a chance for admission to the bar, reflecting the turmoil and disruptions of the wartime period. The Supreme Court’s decision in this case was pivotal in reinforcing the integrity and authority of the judicial system during a time when its decisions and the legal framework itself were under close public scrutiny and challenge.
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