DE ROXAS VS CA

DOCTRINE:
Direct contempt vs indirect contempt (based on doctrine list
but honestly the delineation wasnt clear in this case). I think
the main doctrine is more of the fact that forum shopping may
constitute contempt (then go back to Rule 7 for the delineation
as to what constitutes direct vs indirect contempt).

7. Meycauayan filed a complaint for reconveyance, damages and

quieting of title which was an exact replica of its petitions for
intervention. It also filed a Special Appearance Questioning Court
Jurisdiction and Opposition to the Motion for Issuance of Writ of
Possession Against Meycauayan Central Realty Corporation
8. The RTC deferred ruling on the reconveyance pending the SCs
resolution on a petition for contempt against Meycauayan. It later
dismissed the petitions due to res judicata and that the motion to
annul SC decision was beyond their jurisdiction.

FACTS
1. This case stems from a land dispute between the Heirs of Roxas
and Maguesun where the former was awarded the parcels of land at
the CA level.
2. Meycauayan filed a petition for intervention claiming he was a
buyer in good faith of parcels of land which included the ones
awarded to Heirs of Roxas. The petition for intervention and a
subsequent Motion for Reconsideration were denied by the SC. The
decision became final and executory.
3. Following the SC decision, the LRA submitted a report to the RTC
(as land registration court) praying for the issuance of a decree in
favor of the Heirs of Roxas (as well as the cancellation of
Maguesuns titles and all other derivative titles).
4. Meycauayan filed a Motion For Leave To Intervene And For
Period Of Time To File Opposition To The Report Dated March 25,
1998 Filed By The LRA And To File Complaint-in-Intervention.
5. Heirs of Roxas filed Motions for Clarification questioning among
others whether an order from the RTC was necessary for the LRA to
comply with the SC decision; and whether Meycauayan is guilty of
forum shopping for again filing an intervention now before the RTC.
6. The SC granted the Motions for Clarification and ordered the LRA
to execute the decision without the RTCs order. Heirs of Roxas filed
a Motion for Issuance of Writ of Possession.

9. Meanwhile, Heirs of Roxas also filed a petition to cite Meycauayan

for indirect contempt. In the petition they allege their refusal for
abiding by the SCs decision, their acts of filing for pleadings to stay
its execution and that the action for reconveyance urges the RTC to
countermand the orders of the court. Meycauyan argues that the
decision is not binding upon them since they were not brought as a
party to the case.
ISSUES
1. Whether Meycauayans act of filing the complaint for
reconveyance of lands subject to the SCs final decision,
constitutes indirect contempt
2. Whether Meycauayan is guilty of forum shopping
HELD
1. YES. Their refusal to abide by the SCs final decision has no
basis. The cancellation of all titles in favor of the Heirs of Roxas
should have laid to rest its binding effect on Meycauayan. Their
defiance of the final decision by filing a reconveyance suit over the
same parcels of land constitutes indirect contempt under Rule 71
Sec 3(d):
SEC. 3. Indirect contempt to be punished after charge and
hearing. After a charge in writing has been filed, and an
opportunity given to the respondent to comment thereon within such

period as may be fixed by the court and to be heard by himself or

counsel, a person guilty of any of the following acts may be punished
for indirect contempt:
(d) Any improper conduct tending, directly or indirectly, to impede,
obstruct, or degrade the administration of justice;
The court further discusses contempt as an inherent right and
defines it to be acts in opposition to its authority or interference that
prejudice other litigants.
2. YES. The act of filing a complaint for reconveyance raising the
same issues which the court has already denied, constitute forum
shopping. It is an abuse of the courts processes and constitute
direct contempt. Rule 7 Sec 5

if the acts of the party or his counsel clearly constitute willful and
deliberate forum shopping, the same shall be a ground for summary
dismissal with prejudice and shall constitute direct contempt, as well
as a cause for administrative sanctions.
Their act of disclosing their attempts to intervene does not negate
the existence of forum shopping. The corporation and its
officers/agents may be held liable for direct contempt.