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FREEDOM OF EXPRESSION-People Vs Alarcon

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29 views1 page

FREEDOM OF EXPRESSION-People Vs Alarcon

case digest

Uploaded by

lessej.dimapilis
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© © All Rights Reserved
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People vs Alarcon, G.r. no.

46551, December 12, 1939

FACTS:

As an aftermath of the decision rendered by the Court of First Instance of Pampanga in Criminal Case No.
5733, The People of the Philippines vs. Salvador Alarcon, et al., convicting the accused therein except
one of the crime of robbery committed in band, a denunciatory letter, signed by Luis M. Taruc, was
addressed to His Excellency, the President of the Philippines. A copy of said letter found its way to the
herein respondent, Federico Mangahas who, as columnist of the Tribune, a newspaper of general
circulation in the Philippines, quoted the letter in an article published by him in the issue of that paper of
September 23, 1937.

0n September 29, 1937, the provincial fiscal of Pampanga filed with the Court of First Instance of that
province to cite Federico Mangahas for contempt. 0n the same date, the lower court ordered Mangahas
to appear and show cause. Mangahas appeared and filed an answer, alleging, among others, that "the
publication of the letter in question is in line with the constitutional guarantee of freedom of the press.

ISSUE: Whether the trial court properly cited Mangahas for contempt in as much as the robbery-in-a-
band case is still pending appeal?

RULING:

NO.
The legal parameters surrounding contempt by newspaper publications have been clearly delineated in
this and other jurisdictions. Such contempt is constituted by publications aiming to impede, obstruct,
embarrass, or influence courts in administering justice in ongoing proceedings, and is punishable by the
courts. However, this rule does not apply once a case is concluded. The core issue is whether such
publications genuinely hinder the administration of justice. The authority to address such contempt
shifts to the appellate court once an appeal is lodged, as each court operates independently within the
integrated judicial system.

The argument that the publication scandalized the court, thus warranting the trial court's jurisdiction to
punish for contempt, is disputed. While common law tradition allows for such actions, modern legal
trends lean towards unrestricted commentary on concluded cases under constitutional guarantees of
press freedom. The prevailing rule in this jurisdiction is that contemptuous publications are punishable
only during ongoing proceedings. Contempt of court is viewed as a criminal offense, and any doubt
regarding guilt must be resolved in favor of the accused. Consequently, the order under appeal is
overturned, and the respondent is acquitted without costs.

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