Oca vs. Custodio

A party in an intra-corporate controversy may be held in indirect contempt for willfully disobeying an immediately executory court order even while that order’s validity is being challenged in another proceeding; non-parties, however, may be cited for contempt only upon proof of conspiracy in violating the order.

St. Francis School of General Trias, Cavite, Inc. was established on July 9, 1973 by Laurita Custodio, Cirila N. Mojica, Josefina Pascual, Monsignor Felix Perez, and Brother Vernon Poore, with the assistance of the La Salle brothers. The incorporators served as the school’s Board of Trustees until Perez and Poore passed away, and on September 8, 1988 the incorporators and the La Salle brothers formalized an arrangement under a Memorandum of Agreement whereby De La Salle Greenhills would supervise the school’s academic affairs and appoint supervisors to sit on the Board without voting rights. The governance dispute that followed concerned the scope of La Salle’s supervision over the school’s finances, administration, and operations, and it unfolded within the framework of the Corporation Code and the Interim Rules of Procedure for Intra-Corporate Controversies (A.M. No. 01-2-04-SC).

St. Francis School of General Trias, Cavite, Inc. was established on July 9, 1973 by Laurita Custodio, Cirila N. Mojica, Josefina Pascual, Monsignor Felix Perez, and Brother Vernon Poore. The five incorporators served as the school’s Board of Trustees until Perez and Poore passed away. Although there was no written agreement at first, the La Salle brothers agreed to give the necessary supervision to establish the school’s academic foundation, and on September 8, 1988 the incorporators and the La Salle brothers formalized the arrangement in a Memorandum of Agreement under which De La Salle Greenhills would supervise the academic affairs of St. Francis School to increase enrollment. La Salle appointed supervisors to sit on the Board of Trustees without voting rights. In 1998, Bro. Bernard Oca became a La Salle-appointed supervisor, sat on the Board, and was later elected Chairman and President; in 2000, Bro. Dennis Magbanua was admitted as a La Salle-appointed supervisor, sat as trustee, and was later elected Treasurer.

In August 2001, the Board of Trustees disagreed over the school’s administrative structure and La Salle’s supervision. Cirila, Josefina, Bro. Oca, and Bro. Magbanua wanted to expand the scope of La Salle’s supervision to include matters relating to the school’s finances, administration, and operations, while Custodio opposed the expansion. After several incidents relating to the disagreement, Custodio filed a complaint on June 7, 2002 with Branch 23, Regional Trial Court, Trece Martires, Cavite against St. Francis School, Bro. Oca, and Bro. Magbanua, alleging that Bro. Oca and Bro. Magbanua were never qualified to sit on the Board and praying for a temporary restraining order to prevent Bro. Oca from calling a special membership meeting to remove her from the Board. That case was dismissed, and Custodio was subsequently removed from the Board of Trustees and as Curriculum Administrator. She filed a motion for reconsideration but eventually withdrew her appeal to file a new suit.

On October 3, 2002, Custodio filed a complaint against petitioners for violating the Corporation Code with Branch 21, Regional Trial Court, Imus, Cavite. She sought to disqualify Bro. Oca and Bro. Magbanua as members and trustees and to declare void all their acts as President and Treasurer, and she prayed for a temporary restraining order and/or preliminary injunction to enjoin the remaining board members from holding meetings and to prevent Bro. Oca and Bro. Magbanua from discharging their functions. The case was docketed as SEC Case No. 024-02. On October 8, 2002, the Regional Trial Court heard Custodio’s prayer for a temporary restraining order. The day after the hearing, Custodio filed a Manifestation and Motion dated October 9, 2002, alleging that after the hearing, counsel for petitioners went to St. Francis School to instruct several parents not to acknowledge Custodio’s administration because she had been removed and her complaint dismissed, and that the parents were directed to pay matriculation fees exclusively to Alejandro N. Mojica, son of Cirila, who held office at the Rural Bank of General Trias, Inc. allegedly owned by the family of Josefina. The meeting allegedly caused 15 teachers to hold a strike, nearly disrupted classes, and caused parents to request early dismissal. Custodio reiterated her prayer for a temporary restraining order and moved that the hearing be converted into an injunction hearing or that a status quo order be issued to allow her to continue functioning as school director and curriculum administrator. She also filed a Motion for Clarification praying that the trial court clarify to whom the school’s fees should be paid while her Complaint and Manifestation and Motion were pending. Petitioners allegedly manifested that payment of matriculation fees must be made to Alejandro, but Custodio pointed out that Alejandro was not the school cashier and that the Rural Bank of General Trias, Inc. was not authorized to receive payments for St. Francis School. She also manifested that prior to October 8, 2002, the school cashier was Ms. Herminia Reynante. The Motion was set for hearing on October 18, 2002.

On October 21, 2002, the Regional Trial Court issued an Order designating Reynante to act as school cashier with authority to collect all fees and, together with Custodio, to pay all accounts. The trial court also directed all parties in the case, as well as Mr. Al Mojica, to turn over to Reynante all money previously collected and to submit a report on what had been collected, how much, from whom, and the dates collected, and required Reynante to submit monthly reports effective October 22, 2002. Petitioners filed a motion for reconsideration, alleging that they would have proven that Reynante lacked the moral integrity to act as court-appointed cashier had they been given the opportunity to be heard; the trial court denied reconsideration on January 3, 2003. On February 21, 2003, petitioners filed an Explanation, Manifestation and Compliance, alleging that they partially complied with the October 21, 2002 Order by submitting an accounting on tuition fee collections and by turning over to Reynante a manager’s check in the amount of ₱397,127.64 payable to St. Francis School, representing matriculation fees from October to December 2002. They alleged that Reynante refused to accept the check and required that the amount be turned over in cash or in a check payable to cash, so they placed the check in the custody of the Regional Trial Court for safekeeping.

Custodio filed a Comment dated February 26, 2003, manifesting that petitioners did not even substantially comply with the October 21, 2002 Order because they excluded from their accounting and turnover the following amounts: (1) ₱4,339,601.54 deposited in Special Savings Deposit No. 239 of the Rural Bank of General Trias, Inc.; (2) ₱5,639,856.11 deposited in Special Savings Deposit No. 459 of the Rural Bank of General Trias, Inc.; (3) ₱92,970.00 representing fees paid by the school canteen; and (4) all other fees collected from January 2003 to February 19, 2003. Custodio also claimed that petitioners violated the trial court order that only she and Reynante were authorized to pay the outstanding accounts of St. Francis School by making salary payments to four employees who had resigned. On March 24, 2003, the Regional Trial Court issued another Order directing petitioners to fully comply with its earlier order to submit a report and to turn over to Reynante all the money they had collected, more particularly the listed amounts and an accounting on how and how much defendants were paying Ms. Daisy Romero and three other teachers who had already resigned. Petitioners filed a Manifestation, Observation, Compliance, Exception and Motion on April 18, 2003, praying that the trial court exclude from its March 24, 2003 Order the amounts which were not covered in its October 21, 2002 Order. On August 5, 2003, the Regional Trial Court denied all motions raised in that pleading, ruled that the motion to set aside the orders was a prohibited pleading under Section 8 of the Interim Rules of Procedure for Intra-Corporate Controversies (A.M. No. 01-2-04-SC), and declared that petitioners had not complied with the March 24, 2003 Order. Meanwhile, La Salle served Custodio a notice dated January 4, 2003 that it was terminating the Memorandum of Agreement with St. Francis School. On August 21, 2003, the Regional Trial Court issued an Order granting Custodio’s Manifestation and Motion dated October 9, 2002 and issuing a status quo order allowing Custodio to discharge her functions as school director and curriculum administrator. The trial court found that petitioners had already established another school, the Academy of St. John in Sta. Clara, General Trias, Cavite, which offered the same courses as St. Francis School and was in direct competition with it, creating a conflict of interest for Josefina and Cirila.

Petitioners filed a Motion for Clarification, alleging that the bulk of the money ordered to be turned over to Custodio and Reynante was allotted to St. Francis School’s teachers’ retirement fund and asking whether Custodio and Reynante would use the money for other purposes, whether they would be required to file a bond, and who would be liable for unlawful use. On September 2, 2003, Custodio filed the Petition to Cite Respondents in Contempt of Court under Rule 71 of the Rules of Court, praying that an order be issued reiterating the Orders dated October 21, 2002, March 24, 2003, and August 5, 2003. In response to petitioners’ Motion for Clarification, the trial court issued an Order dated October 8, 2003 clarifying that the retirement fund was to be held in trust by Custodio and Reynante, directing them to file a bond of ₱300,000.00 each, and ordering petitioners to comply with the mandate in the March 24 and August 5, 2003 Orders and to disclose the total amount of the fund deposited and reserved for teachers’ retirement benefit and its bank details. Petitioners still did not comply; instead, they argued in the contempt proceeding that the March 24 and August 5, 2003 Orders were unlawful and were being questioned in G.R. No. 174996, and claimed that their availment of legal remedies showed good faith. During the contempt trial, Custodio presented as her lone witness Joseph Custodio, St. Francis School’s finance and property resource development administrator, while petitioners did not present any witness. The trial court found that petitioners had not complied with the March 24, 2003 Order and credited Joseph’s testimony that the amounts deposited in the Special Savings Accounts were funds for the operations of the school. The Court of Appeals found that petitioners did not remit all the money they had previously collected despite the October 21, 2002 Order, that the March 24, 2003 Order merely reiterated the earlier order, and that petitioners’ defiance amounted to contumacious conduct.

• Good Faith Compliance / Scope of October 21, 2002 Order: Petitioners argued that they complied in good faith because the October 21, 2002 Order pertained only to the school’s matriculation fees and not to any other fees, as it was issued in response to Custodio’s Motion for Clarification dated October 14, 2002, which only requested that the matriculation fees be turned over to Reynante.
• Due Process / Expansion of Order: Petitioners maintained that they were denied due process because Custodio’s Comment to their February 19, 2003 Explanation surreptitiously included a prayer for the turnover of other funds, making it a litigated motion that should have been set for hearing; the March 24, 2003 Order allegedly expanded the scope of the October 21, 2002 Order and required additional sums not included therein, rendering the March 24 and August 5, 2003 Orders unlawful.
• Pending Certiorari / Judicial Courtesy: Petitioners contended that the validity of the March 24 and August 5, 2003 Orders was being questioned in G.R. No. 174996, that their resort to legal remedies showed good faith, and that the Court of Appeals’ ruling was premature because it should have waited for the Supreme Court’s finding on the orders’ validity; they argued that to be charged with indirect contempt, the violated order must be lawful.
• Reasonable Doubt: Petitioners held that contempt proceedings are similar to criminal proceedings, so their guilt must be proven beyond reasonable doubt; they asserted that the circumstances showed reasonable doubt on their guilt and that acquittal was warranted.
• Non-Parties Alejandro and Atty. Silvestre: Petitioners argued that Alejandro N. Mojica and Atty. Silvestre Pascual ought to be dropped as parties because they were not parties in SEC Case No. 024-02, were not subject to the trial court’s jurisdiction, and could not have been aware of the trial court’s orders; there was no showing that they acted in conspiracy with the other petitioners, and guilt could not be assumed or based on mere inference.

• Willful Disobedience / Partial Compliance: Custodio argued that there was clear and contumacious defiance of the trial court orders and that petitioners’ guilt was established beyond reasonable doubt; petitioners only remitted the matriculation fees in the amount of ₱397,127.64, did not render a report on or turn over any other amounts, and only partially complied with the trial court orders.
• Unauthorized Payments: Custodio pointed out that petitioners paid the salaries of four teachers who had already resigned despite the trial court order that only Custodio and Reynante were authorized to settle St. Francis School’s accountabilities.
• Due Process Afforded: Custodio averred that petitioners were afforded due process; her Motion for Clarification dated October 14, 2002 was set for hearing on October 18, 2002, which was attended by petitioners’ counsel, and petitioners’ Explanation, Manifestation and Compliance dated February 19, 2003 was heard by the trial court; if petitioners wanted to assail her Comment, they could have filed a Reply.
• Orders Valid and Entitled Respect: Custodio insisted that the March 24, 2003 Order was a clarification, not an expanded version, of the October 21, 2002 Order; the March 24, 2003 Order was not among the orders questioned in G.R. No. 174996, showing that petitioners were not acting in good faith; the trial court orders are deemed valid and entitled to respect while not yet reversed by a higher court.
• Abuse of Court Processes: Custodio posited that petitioners filed prohibited pleadings under A.M. No. 01-2-04-SC—their Motion for Reconsideration dated November 8, 2002, Explanation, Manifestation, and Compliance dated February 19, 2003, Manifestation, Observation, Compliance, Exception and Motion dated April 18, 2003, and Motion for Clarification dated September 1, 2003—and abused court processes to avoid compliance with the trial court orders.
• Liability of Alejandro and Atty. Silvestre: Custodio claimed that Alejandro and Atty. Silvestre were equally guilty of indirect contempt; Alejandro collected the matriculation fees for the school, while Atty. Silvestre, as a member of the Board of Trustees, was empowered to cause compliance with court orders.
• Factual Issues Improper: Custodio pointed out that petitioners’ raising of factual issues was not proper in a Petition for Review on Certiorari.

• Willful Disobedience: Whether petitioners are guilty of indirect contempt for willful disobedience of the Regional Trial Court Orders dated October 21, 2002 and March 24, 2003.
• Due Process and Scope of Orders: Whether the March 24, 2003 and August 5, 2003 Orders expanded the October 21, 2002 Order and denied petitioners due process.
• Pending Challenge to Validity: Whether petitioners may refuse to comply with the Regional Trial Court orders on the premise that their legality is being questioned in G.R. No. 174996.
• Nature of Contempt and Proof: Whether the contempt proceeding is civil or criminal and whether proof beyond reasonable doubt is required to establish guilt.
• Liability of Non-Parties: Whether Alejandro N. Mojica and Atty. Silvestre Pascual are equally guilty of indirect contempt despite not being parties to SEC Case No. 024-02.

• Willful Disobedience: Yes as to petitioners Oca, Magbanua, Cirila, and Josefina. Their refusal to turn over all monies despite the clear October 21, 2002 Order and its reiterations constituted willful disobedience under Rule 71, Section 3(b) of the Rules of Court.
• Due Process and Scope of Orders: No. The March 24 and August 5, 2003 Orders did not expand the October 21, 2002 Order, which already covered all collectibles, fees, and accounts; petitioners were afforded opportunity to be heard, as settled in Oca vs. Custodio.
• Pending Challenge to Validity: No. Under Section 4 of the Interim Rules of Procedure for Intra-Corporate Controversies, all orders in intra-corporate controversies are immediately executory, and questioning them does not stay enforcement absent an appellate restraint; judicial courtesy does not apply because the validity issue and the contempt issue are separate.
• Nature of Contempt and Proof: Civil contempt. The proceeding was more civil than criminal because Custodio sought enforcement of the orders for her benefit; proof beyond reasonable doubt was not required.
• Liability of Non-Parties: No. Alejandro N. Mojica and Atty. Silvestre Pascual cannot be held guilty absent proof of conspiracy; Alejandro merely collected fees as cashier, and Atty. Silvestre, as one board member, was not empowered to cause compliance.

• Willful Disobedience: Contempt of court is willful disobedience to the court and disregard or defiance of its authority, justice, and dignity; it constitutes conduct that tends to bring the authority of the court and the administration of law into disrepute or to impede the due administration of justice. All courts have the inherent power to punish contempt, and indirect contempt under Rule 71, Section 3 includes disobedience of or resistance to a lawful writ, process, order, or judgment. The October 21, 2002 Order directed the turnover of “all money previously collected” and referred to “all collectibles,” “all fees,” and “all accounts”; it did not limit turnover to matriculation fees. Custodio’s Motion for Clarification also covered “matriculation fees and other fees.” The March 24, 2003 Order merely specified the amounts and reiterated compliance, while the August 5, 2003 Order found noncompliance. Despite these orders and the October 8, 2003 clarification, petitioners refused to comply, filing numerous pleadings and insisting they had complied by remitting only ₱397,127.64. The trial court lent credence to Joseph’s testimony that the Special Savings Accounts were operational funds; in any event, the trial court had determined custody during the intra-corporate case. This repeated refusal showed contumacious conduct and abuse of court processes.
• Due Process and Scope of Orders: Petitioners claimed denial of due process because Custodio’s Comment allegedly inserted a surreptitious prayer and the March 24 Order expanded the October 21 Order. The Court found no expansion: the October 21 Order already directed turnover of all fees, and Custodio’s Comment merely specified amounts not remitted and sought compliance. The trial court’s August 5 Order denied petitioners’ motion as a prohibited pleading under Section 8 of the Interim Rules. Petitioners attended hearings and filed several pleadings, and in Oca vs. Custodio the Supreme Court already ruled that they were not denied due process in the issuance of the August 5, August 21, and October 8, 2003 Orders. Due process requires opportunity to be heard, not necessarily a formal hearing on every pleading.
• Pending Challenge to Validity: Section 4 of the Interim Rules provides that all decisions and orders in intra-corporate controversies are immediately executory except awards for moral damages, exemplary damages, and attorney’s fees, and no appeal or petition stays enforcement unless restrained by an appellate court. No injunction restrained the trial court orders. Parties cannot decide for themselves whether to comply. Judicial courtesy, which allows suspension of lower court proceedings to avoid mooting an issue in a higher court, did not apply because G.R. No. 174996 concerned validity while the contempt case concerned willful disobedience; a finding of contempt would not moot the validity issue. Roxas vs. Tipon recognized that a party may be cited for contempt although the disobeyed order is pending review.
• Nature of Contempt and Proof: Contempt has civil and criminal aspects. Civil contempt is failure to do something ordered for the benefit of the opposing party; its purpose is to compel obedience and preserve a private party’s right. Criminal contempt is conduct against the authority and dignity of the court and is punitive. In civil contempt, proof need not be beyond reasonable doubt but must be more than a mere preponderance of evidence. The proceeding here was more civil than criminal because Custodio sought enforcement of the trial court orders in the intra-corporate controversy after petitioners refused compliance. The fine and order to comply served both punitive and coercive purposes, but the dominant purpose was remedial. Thus, proof beyond reasonable doubt was not required, and willful disobedience was sufficiently proven.
• Liability of Non-Parties: Under Ferrer vs. Rodriguez, non-parties may be cited for contempt for willful violation of an order if they conspired with a party in violating it. No evidence of conspiracy existed. Alejandro merely collected matriculation fees as a designated cashier at the Rural Bank; he had no power over the money or authority to decide its custody, and the fees had already been turned over to Reynante. Atty. Silvestre was a Board member, but board decisions are not controlled by one member; a board member may be outvoted and is not individually empowered to cause compliance. The burden of proving contempt rests on the complainant, and there is no presumption of guilt. Without proof of conspiracy, both must be dismissed.

• Indirect Contempt by Disobedience of a Lawful Court Order — Rule 71, Section 3(b) of the Rules of Court defines indirect contempt to include disobedience of or resistance to a lawful writ, process, order, or judgment of a court. The Court applied this doctrine to petitioners’ repeated refusal to turn over all monies as directed by the October 21, 2002 Order and its reiterations, holding that such refusal constituted willful disobedience.
• Immediately Executory Nature of Orders in Intra-Corporate Controversies — Under Section 4 of the Interim Rules of Procedure for Intra-Corporate Controversies (A.M. No. 01-2-04-SC), all decisions and orders issued under the Rules are immediately executory except awards for moral damages, exemplary damages, and attorney’s fees, and no appeal or petition taken therefrom stays enforcement unless restrained by an appellate court. The Court applied this rule to hold that petitioners could not refuse compliance merely because they were questioning the orders’ validity in G.R. No. 174996, since no appellate court had restrained enforcement.
• Judicial Courtesy — Judicial courtesy is exercised by suspending a lower court’s proceedings although there is no injunction or order from a higher court; its purpose is to avoid mooting the matter raised in the higher court, and it applies only if the continuation of the lower court’s proceedings will render moot the issue raised in the higher court. The Court held it inapplicable because G.R. No. 174996 concerned the validity of the orders while the contempt case concerned whether petitioners willfully disobeyed them; the contempt finding would not moot the validity issue.
• Civil and Criminal Contempt — Civil contempt is the failure to do something ordered by a court for the benefit of the opposing party; it is remedial and coercive, and its purpose is to compel obedience to an order for the benefit of a private party. Criminal contempt is conduct directed against the authority and dignity of the court and is punitive. In civil contempt, proof need not be beyond reasonable doubt but must amount to more than a mere preponderance of evidence; in criminal contempt, guilt must be proven beyond reasonable doubt. The Court characterized the proceeding as more civil than criminal because Custodio sought enforcement of the trial court orders, and thus proof beyond reasonable doubt was not required.
• Non-Litigants May Be Cited for Contempt Only Upon Proof of Conspiracy — Persons who are not parties to a proceeding may be declared guilty of contempt for willful violation of an order issued in the case if they are guilty of conspiracy with any of the parties in violating the court’s order. The Court applied this doctrine to dismiss the charges against Alejandro N. Mojica and Atty. Silvestre Pascual, finding no evidence of conspiracy; Alejandro merely collected fees as a cashier, and Atty. Silvestre, as one board member, was not individually empowered to cause compliance.
• Contempt Power Must Be Exercised Cautiously, Sparingly, and Judiciously — While courts have the inherent power to punish contempt, this power must be exercised cautiously, sparingly, and judiciously, and may be used to maintain respect due to the court where defiance is clear and contumacious. The Court applied this principle by affirming the contempt conviction of the petitioners who clearly refused to comply, but dismissing the charges against the non-parties absent sufficient evidence.

• “Plaintiff and defendants, as well as Mr. Al Mojica, are directed to turn-over to Ms. Herminia Reynante all money previously collected and to submit a report on what have been collected, how much, from whom, and the dates collected.” — This passage from the October 21, 2002 Order is central to the Court’s finding that the order covered all money previously collected, not merely matriculation fees, thereby defeating petitioners’ claim of good-faith partial compliance.
• “The wording of the October 21, 2002 Order is clear that the amounts do not pertain only to the matriculation fees but to all collectibles, all fees, and all accounts.” — This is the ratio decidendi on the scope of the order; it directly rejects petitioners’ argument that the March 24, 2003 Order expanded the earlier order.
• “Questioning the trial court orders does not stay its enforcement or implementation. There is no showing that the trial court orders were restrained by the appellate court.” — This passage states the controlling rule on the immediately executory nature of intra-corporate orders and explains why petitioners could not justify noncompliance by filing a separate certiorari petition.
• “In the absence of proof of conspiracy, it cannot be said that Alejandro and Atty. Silvestre are guilty of contempt.” — This excerpt encapsulates the Court’s ruling that non-parties may be cited for indirect contempt only upon proof of conspiracy, which was lacking as to Alejandro N. Mojica and Atty. Silvestre Pascual.

• Sison vs. Caoibes, Jr., 473 Phil. 251 (2004) — Cited for the inherent power of courts to punish contempt and for the definition of contempt as a means to protect the dignity of the court and the administration of justice.
• Oca vs. Custodio, 749 Phil. 186 (2014) — Prior related case in G.R. No. 174996; the Supreme Court upheld the August 5 and October 8, 2003 Orders, set aside the August 21, 2003 Status Quo Order for grave abuse of discretion, and ruled that petitioners were not denied due process.
• Roxas vs. Tipon, 688 Phil. 372 (2012) — Followed for the rule that a party may be cited for indirect contempt for refusing to obey a standing order even while the order’s validity is pending before the Court of Appeals.
• Halili vs. Court of Industrial Relations, 220 Phil. 507 (1985) — Cited for the definition and classification of contempt into civil and criminal, and for the twofold aspect of contempt as punishment and coercion.
• People vs. Godoy, 312 Phil. 977 (1995) — Cited for the distinction between civil and criminal contempt and the differing evidentiary burdens; civil contempt does not require proof beyond reasonable doubt.
• Ferrer vs. Rodriguez, 116 Phil. 1 (1962) — Cited for the rule that non-litigants may be cited for contempt for willful violation of an order if they conspired with a party in violating it.
• Province of Camarines Norte vs. Province of Quezon, 419 Phil. 372 (2001) — Cited for the principle that the power to cite contempt should be used sparingly but may be exercised where defiance is clear and contumacious.
• Balindong vs. Court of Appeals, G.R. Nos. 177600 & 178684, October 19, 2015 — Cited for the rule that the power to punish contempt must be exercised cautiously, sparingly, and judiciously.
• Sara Lee Phils., Inc. vs. Macatlang, 750 Phil. 646 (2015) — Cited for the doctrine of judicial courtesy and its requirement that continuation of lower court proceedings would moot the issue raised in the higher court.

• Rule 71, Section 3(b), Rules of Court — Defines indirect contempt to include disobedience of or resistance to a lawful writ, process, order, or judgment of a court; the Court applied this provision to petitioners’ refusal to turn over all monies as directed.
• Rule 71, Section 3, Rules of Court — Enumerates the acts constituting indirect contempt and requires a written petition and opportunity to be heard; the contempt case proceeded under this Rule.
• Rule 71, Section 1, Rules of Court — Defines direct contempt as misbehavior in the presence of or so near a court as to obstruct or interrupt proceedings; cited to distinguish direct from indirect contempt.
• Section 4, Interim Rules of Procedure for Intra-Corporate Controversies (A.M. No. 01-2-04-SC) — Provides that all decisions and orders in intra-corporate controversies are immediately executory except awards for moral damages, exemplary damages, and attorney’s fees, and that no appeal or petition stays enforcement unless restrained by an appellate court; applied to reject petitioners’ refusal pending G.R. No. 174996.
• Section 8, Interim Rules of Procedure for Intra-Corporate Controversies (A.M. No. 01-2-04-SC) — Prohibits certain pleadings, including motions for reconsideration; the trial court treated petitioners’ motion to set aside the orders as a prohibited pleading under this section.
• Rule 45, Rules of Court — Governs the Petition for Review on Certiorari filed by petitioners; the Court resolved the petition under this Rule.

Antonio T. Carpio (Chairperson), Diosdado M. Peralta, Jose Catral Mendoza, and Samuel R. Martires concurred. No separate concurring opinions are summarized in the text.