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Welcome to the Supreme Court of the Philippines
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SC Finds Lorraine Badoy Guilty of Indirect Contempt for Attacks against Judge; Warns Online Influencers to Verify Truthfulness of Posts

February 29, 2024

“By merely having access to social media, private individuals could publish their thoughts without need of self-policing or adhering to the ethical standards required of the press. As a result, content could be created and shared with abandon, purely for clout or for ‘likes,’ and even in disregard of the truth.”

Thus lamented the Supreme Court En Banc, in a Decision penned by Senior Associate Justice Marvic M.V.F. Leonen, as it found Lorraine Marie T. Badoy-Partosa (Badoy) guilty of indirect contempt of court for statements she made online attacking Judge Marlo A. Magdoza-Malagar (Judge Magdoza-Malagar) of the Regional Trial Court of Manila, Branch 19.

On September 21, 2022, Judge Magdoza-Malagar issued a Resolution dismissing the petition of the Department of Justice (DOJ) to proscribe the Communist Party of the Philippines (CPP)-New People’s Army (NPA) as a terrorist group under the Human Security Act.

Two days after, Badoy uploaded a public post on her Facebook page where she launched multiple insults against Judge Magdoza-Malagar. Badoy claimed that the judge was friends with the CPP-NPA-National Democratic Front (NDF) and that the judge “weaponiz[ed] a court of law to further inflict harm on a people that have long suffered the excesses and inhumanities of the CPP-NPA-NDF.”

Badoy also threatened to kill Judge Magdoza-Malagar: “So if I kill this judge and I do so out of my political belief that all allies of the CPP NPA NDF must be killed because there is no difference [in my mind] between a member of the CPP NPA NDF and their friends, then please be lenient with me.”

In a second post on the same day, Badoy further threatened to bomb the offices of judges whom Badoy deemed as “friends of terrorists.”

The next day, Badoy uploaded another post, describing Judge Magdoza-Malagar as “unprincipled and rotten” and claiming that the judge’s husband was a member of the CPP.

The posts made by Badoy, who has over 166,000 Facebook followers, generated comments, remarks, images, and videos of the same vitriol as her posts, openly supporting her statements and even offering assistance. Some posts even asked for Judge Magdoza-Malagar’s address. Badoy would later compile these responses and upload as another post.

Badoy’s statements prompted a group of lawyers to file a petition before the Court to cite her for indirect contempt.

In resolving the petition, the Court stressed the need to balance the exercise of free speech and the protection of judicial independence.

“One’s right to freedom of expression must be as fully protected as possible; however, its exercise must never transgress the equally important aspects of democracy, not least of all the Judiciary’s dignity and authority,” held the Court.

Thus, while the freedoms of expression, speech, and the press include the right to criticize judicial conduct, such exercise must not threaten judicial independence.

To ensure judicial independence, courts possess the inherent power to punish for contempt. This power is considered “a permissible subsequent punishment for those who abuse their constitutional freedoms of speech, of expression, and of the press.

Direct contempt is committed when one engages in “misbehavior in the presence of or so near a court as to obstruct or interrupt the proceedings” while indirect contempt involves actions that are committed not within the presence of the court, including improper conduct tending, directly or indirectly, to impede, obstruct, or degrade the administration of justice.

The power to cite for contempt is essential to preserve order in judicial proceedings, and for courts to enforce their judgments, orders, and mandates and ensure the due administration of justice. This also prevents “the proliferation of untruths which, if unrefuted, would gain an undue influence in the public discourse.”

“Judges who are the subject of fake news in their judicial capacity are prevented by propriety from defending themselves through social media or explaining themselves through a representative. They may only defend themselves in the proper forum—in contempt proceedings,” said the Court.

As explained in its 2008 ruling in In re Macasaet, there is an important line between legitimate criticism and illegitimate attack upon the courts or their judges. “Attacks upon the court or a judge not only risk the inhibition of all judges as they conscientiously endeavor to discharge their constitutional responsibilities; they also undermine the people’s confidence in the courts.”

While contemptuous speech is generally subject to punishment, it may fall under the recognized qualified privileges protected under free speech if: (a) made in good faith and without malice; (b) it is a fair and true reporting of a proceeding or any of its incidents or (c) it is a fair commentary on matters of public interest. To be considered fair, the comment or criticism must be grounded in truth and facts, stressed the Court.

Applying the foregoing to the present case, the Court found that Badoy’s posts constitute improper conduct tending, directly or indirectly, to impede, obstruct, or degrade the administration of justice, which equates to indirect contempt.

Badoy’s assertion that Judge Magdoza-Malagar dismissed the DOJ’s petition because of the judge’s supposed friendly ties with the CPP-NPA-NDF threatens the impartial image of the Judiciary, the Court ruled.

Badoy’s claim that the judge lawyered for one of the parties due to her alleged political leanings similarly harms the court’s administration of justice. Badoy even claimed that the judge was assisted by the CPP-NPA-NDF when she wrote the decision, putting into question its legality.

The Court further found that Badoy failed to allege the existence of any qualified privilege that applied when she published her posts on Facebook.

First, Badoy’s ‘criticisms’ were not made in good faith or without malice. She did not act with an honest sense of duty or with an interest in the pure and efficient administration of justice and public affairs. Instead, she was impelled by a self-seeking motive, which was to stir discontent among her audience, as evidenced by her use of violent and abrasive language in hurling accusations at Judge Magdoza-Malagar.

Second, Badoy’s comments were not a fair and true reporting of a proceeding. On the contrary, Badoy imputed serious allegations against Judge Magdoza-Malagar and the Judiciary without any factual basis, said the Court. Her posts and even the pleadings she filed before the Court do not indicate that she possesses evidence to support her scandalous statements.

Third, her statements were not grounded in truth and facts and, thus, do not constitute “fair commentaries on matters of public interest.”

By alleging that Judge Magdoza-Malagar had basis other than the Constitution and the law in dismissing the proscription case, and by claiming that the decision was written by the winning party, Badoy cast doubt on the decision’s legitimacy. As a result, numerous members of the public prejudged the case, held the Court.

While “mere criticism or comment on the correctness or wrongness, soundness or unsoundness of the decision of the court in a pending case made in good faith may be tolerated,” declarations, such as those made by Badoy, ascribing improper motives to and rounding up public support to exert pressure on Judge Magdoza-Malagar, cannot be seen as criticism done in good faith. “It is nothing but an act of intimidation to influence the resolution of a pending case,” the Court stressed.

The Court further clarified that malicious imputations made even after the finality of a decision still fall under contemptuous speech if they tend to disrespect the court or create clear and present danger in the administration of justice.

The Court also found that Badoy’s “explosive statements” threatening to kill Judge Magdoza-Malagar and other judges were clearly made to incite Badoy’s followers and produce imminent lawless action, as evidenced by the multiple comments subsequently posted openly supporting the statements and even offering assistance. Some have even gone as far as asking for Judge Magdoza-Malagar’s address, a clear sign that they intended to execute Badoy’s call.

Such incitement to commit lawless violent action likely to cause death or injury is not covered by the constitutional privilege of protected speech, stressed the Court. “As shown by past experiences here and abroad, when such incitement to cause lawless violent action is done through social media by its influencers, the imminence is high that it will actually be committed by those so provoked.”

Badoy’s statements, though unsubstantiated, have the power to spark a deluge of assaults against the Judiciary and its members, and thus cannot be dismissed by the Court.

Neither was the Court persuaded by Badoy’s excuse that her post was mere ‘hypothetical syllogism’: “If [Badoy] truly meant no harm, she would have pacified her followers and explained that she was merely employing ‘hypothetical syllogism.’ Instead, [Badoy] continued to post scores of statements further stroking the fire.”

The Court concluded that Badoy’s statements jeopardized the Judiciary by “sowing distrust and impairing the public’s confidence in the honesty, integrity, and impartiality of those donning judicial robes. She was not merely advancing her advocacy when she made those incendiary statements on social media; she effectively made a call to action against Judge Magdoza-Malagar and the entire Judiciary,” said the Court.

Badoy was thus fined PHP 30,000 and warned that a repetition of the same or similar acts in the future shall merit a more severe sanction.

The Court also cautioned online personalities and influencers, underscoring that unregulated speech online and the spread of fake news pose real consequences in the real world.

“To maintain their popularity, online personalities tend to publish a steady stream of shocking or attention-grabbing content to take advantage of their audience’s negativity bias, that is, the natural human tendency to latch on to something bad rather than good. In a bid to ensure that their posts would become viral, they would make statements that produce heightened negative emotions, chasing after the dopamine rush brought about by the substantial increase in their followers and likes. The result is a proliferation of posts made to further their personal gain and popularity, without regard for the public good,” said the Court.

The Court further observed how social media’s wide audience, unconstrained by physical reach, has inevitably led to “a glut in disseminated information, a large part of which is disinformation—the ‘verifiably false or misleading information that is created, presented and disseminated for economic gain or to intentionally deceive the public, and may cause public harm’ on the internet.”

Online personalities thus have a duty to verify the truthfulness of the content they put out on the internet. “It behooves them to validate the source of news through fact-checking and even through source-checking, lest they unwittingly disseminate fake news and even cause real-world harm,” warned the Court.  (Courtesy of the Supreme Court Public Information Office)

FULL TEXT of A.M. No. 22-09-16-SC and G.R. No. 263384, Re: Statements made by Lorraine Marie T. Badoy allegedly threatening Judge Marlo A. Magdoza-Malagar and Atty. Rico V. Domingo, et al. v. Lorraine Marie T. Badoy-Partosa (August 15, 2023) at: https://sc.judiciary.gov.ph/22-09-16-sc-263384-re-statements-made-by-lorraine-marie-t-badoy-allegedly-threatening-judge-marlo-a-magdoza-malagar-atty-rico-v-domingo-dean-antonio-gabriel-m-la-vina-dean-ma-soledad-deriquit/

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The Supreme Court Under
the 1987 Constitution

As in the 1935 and 1973 Constitutions, the 1987 Constitution provides that “[t]he judicial power shall be vested in one Supreme Court and in such lower courts as may be established by law.” (Art. VII, Sec. 1). The exercise of judicial power is shared by the Supreme Court with all lower courts, but it is only the Supreme Court’s decisions that are vested with precedential value or doctrinal authority, as its interpretations of the Constitution and the laws are final and beyond review by any other branch of government.

Unlike the 1935 and 1973 Constitutions, however, the 1987 Constitution defines the concept of judicial power. Under paragraph 2 of Section 1, Article VIII, “judicial power” includes not only the “duty of the courts of justice to settle actual controversies involving rights which are legally demandable and enforceable” but also “to determine whether or not there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the government.” This latter provision dilutes the effectivity of the “political question” doctrine which places specific questions best submitted to the political wisdom of the people beyond the review of the courts.

Building on previous experiences under former Constitutions, the 1987 Constitution provides for specific safeguards to ensure the independence of the Judiciary. These are found in the following provisions:

    • The grant to the Judiciary of fiscal autonomy. “Appropriations for the Judiciary may not be reduced by the legislature below the amount appropriated for the previous year, and, after approval, shall be automatically and regularly released.” (Art. VIII, Sec. 3).
    • The grant to the Chief Justice of authority to augment any item in the general appropriation law for the Judiciary from savings in other items of said appropriation as authorized by law. (Art. VI, Sec. 25[5])
    • The removal from Congress of the power to deprive the Supreme Court of its jurisdiction over cases enumerated in Section 5 of Article VIII.
    • The grant to the Court of the power to appoint all officials and employees of the Judiciary in accordance with the Civil Service Law (Art. VIII, Sec. 5 [6])
    • The removal from the Commission of Appointments of the power to confirm appointments of justices and judges (Art. VIII, Sec. 8)
    • The removal from Congress of the power to reduce the compensation or salaries of the Justices and judges during their continuance in office. (Art. VIII, Sec. 10)
    • The prohibition against the removal of judges through legislative reorganization by providing that “(n)o law shall be passed reorganizing the Judiciary when it undermines the security of tenure of its members. (Art. VIII, Sec. 2)
    • The grant of sole authority to the Supreme Court to order the temporary detail of judges. (Art. VIII, Sec. 5[3])
    • The grant of sole authority to the Supreme Court to promulgate rules of procedure for the courts. (Art. VIII, Sec. 5[5])
    • The prohibition against designating members of the Judiciary to any agency performing quasi-judicial or administrative function. (Art. VIII, Sec. 12)
    • The grant of administrative supervision over the lower courts and its personnel in the Supreme Court. (Art. VIII, Sec. 6)

The Supreme Court under the present Constitution is composed of a Chief Justice and 14 Associate Justices. The members of the Court are appointed by the President from a list, prepared by the Judicial and Bar Council, of at least three nominees for every vacancy. This new process is intended to “de-politicize” the courts of justice, ensure the choice of competent judges, and fill existing vacancies without undue delay.


The Supreme Court Under
the Revolutionary Government

Shortly after assuming office as the seventh President of the Republic of the Philippines after the successful People Power Revolution, then President Corazon C. Aquino declared the existence of a revolutionary government under Proclamation No. 1 dated February 25, 1986. Among the more significant portions of this Proclamation was an instruction for “all appointive officials to submit their courtesy resignations beginning with the members of the Supreme Court.” The call was unprecedented, considering the separation of powers that the previous Constitutions had always ordained, but understandable considering the revolutionary nature of the post-People Power government. Heeding the call, the members of the Judiciary—from the Supreme Court to the Municipal Circuit Courts—placed their offices at the disposal of the President and submitted their resignations. President Corazon C, Aquino proceeded to reorganize the entire Court, appointing all 15 members.

On March 25, 1986, President Corazon Aquino, through Proclamation No. 3, also abolished the 1973 Constitution and put in place a Provisional “Freedom” Constitution. Under Article I, Section 2 of the Freedom Constitution, the provisions of the 1973 Constitution on the judiciary were adopted insofar as they were not inconsistent with Proclamation No. 3.

Article V of Proclamation No. 3 provided for the convening of a Constitutional Commission composed of 50 appointive members to draft a new constitution; this would be implemented by Proclamation No. 9. Under the leadership of retired SC Justice Cecilia Muñoz Palma as its President, the Constitutional Commission of 1986 submitted its output of to the people for ratification.

By a vote of 76.30%, the Filipino people then ratified the Constitution submitted to them in a national plebiscite on February 2, 1987.

President Aquino, other civilian officials, and members of the Armed Forces of the Philippines, upon the announcement of the ratification of the 1987 Constitution, swore allegiance to the new charter on February 11, 1987 thereby putting an end to the revolutionary government.


The Supreme Court Under
the 1973 Constitution

The declaration of Martial Law through Proclamation No. 1081 by former President Ferdinand E, Marcos in 1972 brought about the transition from the 1935 Constitution to the 1973 Constitution. This transition had implications on the Court’s composition and functions.

This period also brought in many legal issues of transcendental importance and consequence. Among these were the legality of the ratification of a new Constitution, the assumption of the totality of government authority by President Marcos, and the power to review the factual basis for a declaration of Martial Law by the Chief Executive, among others. Also writ large during this period was the relationship between the Court and the Chief Executive who, under Amendment No. 6 to the 1973 Constitution, had assumed legislative powers even while an elected legislative body continued to function.

The 1973 Constitution increased the number of the members of the Supreme Court from 11 to 15, with a Chief Justice and 14 Associate Justices. The Justices of the Court were appointed by the President alone, without the consent, approval, or recommendation of any other body or officials.


The Supreme Court of
the Second Republic

Following liberation from the Japanese occupation at the end of the Second World War and the Philippines’ subsequent independence from the United States, Republic Act No. 296 or the Judiciary Act of 1948 was enacted. This law grouped together the cases over which the Supreme Court could exercise exclusive jurisdiction for review on appeal, certiorari, or writ of error.


The Supreme Court During
the Commonwealth

Following the ratification of the 1935 Philippine Constitution in a plebiscite, the principle of separation of powers was adopted, not by express and specific provision to that effect, but by actual division of powers of the government—executive, legislative, and judicial—in different articles of the 1935 Constitution.

As in the United States, the judicial power was vested by the 1935 Constitution “in one Supreme Court and in such inferior courts as may be established by law.” It devolved on the Judiciary to determine whether the acts of the other two departments were in harmony with the fundamental law.

The Court during the Commonwealth was composed of “a Chief Justice and ten Associate Justices, and may sit en banc or in two divisions, unless otherwise provided by law.”


The Establishment of
the Supreme Court of the Philippines

On June 11, 1901, the Second Philippine Commission passed Act No. 136 entitled “An Act Providing for the Organization of Courts in the Philippine Islands” formally establishing the Supreme Court of the Philippine Islands and creating Courts of First Instance and Justices of the Peace Courts throughout the land. The judicial organization established by the Act was conceived by the American lawyers in the Philippine Commission, with its basic structures patterned after similar organizations in the United States.

The Supreme Court created under the Act was composed of a Chief Justice and six Judges. Five members of the Court could form a quorum, and the concurrence of at least four members was necessary to pronounce a judgment.

Act No. 136 abolished the Audiencia established under General Order No. 20 and declared that the Supreme Court created by the Act be substituted in its place. This effectively severed any nexus between the present Supreme Court and the Audiencia.

The Anglo-American legal system under which the Supreme Court of the Philippine Islands was expected to operate was entirely different from the old Spanish system that Filipinos were familiar with. Adjustments had to be made; hence, the decisions of the Supreme Court during its early years reflected a blend of both the Anglo-American and Spanish systems. The jurisprudence was a gentle transition from the old order to the new.


The Judicial System During
the American Occupation

After Spain’s defeat in the Spanish-American War in the late 1890s, The subsequent occupation by the Americans of the Philippine Islands paved the way for considerable changes in the control, disposition, and governance of the Islands.

The judicial system established during the regime of the military government functioned as an instrument of the executive—not of the judiciary—as an independent and separate branch of government. Secretary of State John Hay, on May 12, 1899, proposed a plan for a colonial government of the Philippine Islands which would give Filipinos the largest measure of self-government. The plan contemplated an independent judiciary manned by judges chosen from qualified locals and Americans.

On May 29, 1899, General Elwell Stephen Otis, Military Governor for the Philippines, issued General Order No. 20, reestablishing the Audiencia Teritorial de Manila which was to apply Spanish laws and jurisprudence recognized by the American military governor as continuing in force.

The Audiencia was composed of a presiding officer and eight members organized into two divisions: the sala de lo civil or the civil branch, and the sala de lo criminal or the criminal branch.

It was General Otis himself who personally selected the first appointees to the Audiencia. Cayetano L. Arellano was appointed President (equivalent to Chief Justice) of the Court, with Manuel Araullo as president of the sala de lo civil and Raymundo Melliza as president of the salo de lo criminal. Gregorio Araneta and Lt. Col. E.H. Crowder were appointed associate justices of the civil branch while Ambrosio Rianzares, Julio Llorente, Major R.W. Young, and Captain W.E. Brikhimer were designated associate justices of the criminal branch. Thus, the reestablished Audiencia became the first agency of the new insular government where Filipinos were appointed side by side with Americans.


The Judicial System Under
the Spanish Regime

During the early Spanish occupation, King Philip II established the Real Audiencia de Manila which was given not only judicial but legislative, executive, advisory, and administrative functions as well. Composed of the incumbent governor general as the presidente (presiding officer), four oidores (equivalent to associate justices), an asesor (legal adviser), an alguacil mayor (chief constable), among other officials, the Real Audiencia de Manila was both a trial and appellate court. It had exclusive original, concurrent original, and exclusive appellate jurisdictions.

Initially, the Audiencia was given a non-judicial role in the colonial administration, to deal with unforeseen problems within the territory that arose from time to time—it was given the power to supervise certain phases of ecclesiastical affairs as well as regulatory functions, such as fixing of prices at which merchants could sell their commodities. Likewise, the Audiencia had executive functions, like the allotment of lands to the settlers of newly established pueblos. However, by 1861, the Audiencia had ceased to perform these executive and administrative functions and had been restricted to the administration of justice.

When the Audiencia Territorial de Cebu was established in 1886, the name of the Real Audiencia de Manila was changed to Audiencia Territorial de Manila.


The Judicial System of the
Pre-Colonization Filipinos

When the Spanish colonizers first arrived in the Philippine archipelago, they found the indigenous Filipinos without any written laws. The laws enforced were mainly derived from customs, usages, and tradition. These laws were believed to be God-given and were orally transmitted from generation to generation.

A remarkable feature of these customs and traditions was that they were found to be very similar to one another notwithstanding that they were observed in widely dispersed islands of the archipelago. There were no judges and lawyers who were trained formally in the law, although there were elders who devoted time to the study of the customs, usages, and traditions of their tribes to qualify them as consultants or advisers on these matters.

The unit of government of the indigenous Filipinos was the barangay, which was a family-based community of 30 to 100 families, occupying a pook (“locality” or “area”) headed by a chieftain called datu who exercised all functions of government—executive, legislative, and judicial—a barangay was not only a political but a social and an economic organization. In the exercise of his judicial authority, the datu acted as a judge (hukom) in settling disputes and deciding cases in his barangay.

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