JOSE L. GUEVARA vs. COMELEC G.R. No. L-12596 July 31, 1958
FACTS:
Guevara was ordered by the COMELEC to show
cause why he should not be punished for contempt for having published in the
newspaper an article which tended to interfere with and influence the COMELEC
awarding the contracts for the manufacture and supply of ballot boxes;
and which article likewise tended to degrade, bring into disrepute, and
undermine the exclusive constitutional function of this Commission and its
Chairman
Petitioner, filed a motion to quash on the
following ground that the Commission has no jurisdiction to punish as contempt
the publication of the alleged contemptuous article, as neither in the
Constitution nor in statutes is the Commission granted a power to so punish the
same.
ISSUE:
Whether or not the COMELEC has the power
and jurisdiction to conduct contempt proceedings against Guevara in connection
with the publication of an article.
RULING:
Although the negotiation conducted by the
Commission has resulted in controversy between several dealers, that however
merely refers to a ministerial duty which the Commission has performed in its
administrative capacity. It only discharged a ministerial duty; it did not
exercise any judicial function. Such being the case, it could not exercise the
power to punish for contempt as postulated in the law, for such power is
inherently judicial in nature. As this Court has aptly said: "The power to
punish for contempt is inherent in all courts; its existence is essential to
the preservation of order in judicial proceedings, and to the enforcement of
judgments, orders and mandates of courts, and, consequently, in the
administration of justice". We are therefore persuaded to conclude that
the Commission on Elections has no power nor authority to submit petitioner to
contempt proceedings if its purpose is to discipline him because of the
publication of the article mentioned in the charge under consideration.