A Regional Trial Court has no jurisdiction to prohibit the Senate or its committees from conducting inquiries in aid of legislation, as this would violate the principle of separation of powers; furthermore, the use of terms like "gross ignorance of the law" in pleadings challenging a judge's order, without malice, does not automatically constitute indirect contempt, especially when such terms are descriptive of alleged errors in applying fundamental legal principles.

The case arose from two Senate Resolutions: No. 157, directing an inquiry into alleged coup d'etat plans related to probing AFP fund irregularities, and No. 160, directing an inquiry into alleged mismanagement of AFP-Retirement and Separation Benefits System (AFP-RSBS) funds. These resolutions were referred to the Senate Blue Ribbon Committee and the Committee on National Defense and Security for investigation.

• On August 28, 1998, Senator Blas F. Ople filed Senate Resolution No. 157 for an inquiry into alleged coup d'etat plans, and Senator Vicente C. Sotto III filed Resolution No. 160 for an inquiry into alleged mismanagement of AFP-RSBS funds.
• During public hearings by the Senate Blue Ribbon Committee, it was revealed that AFP-RSBS purchased Lot X, MR-1160, in General Santos City from Atty. Nilo J. Flaviano for P10,500.00 per square meter, but the deed of sale indicated only P3,000.00 per square meter.
• The Committee subpoenaed Atty. Flaviano, who refused to appear and instead filed a petition for prohibition and preliminary injunction (SP Civil Case No. 496) with the RTC of General Santos City, Branch 23, presided by Judge Jose B. Majaducon.
• On October 21, 1998, Judge Majaducon issued a TRO directing the Committee to cease its inquiry regarding the Lot X sale and from issuing subpoenas to witnesses from Region XI.
• On November 5, 1998, the Committee moved to dismiss Flaviano's petition for lack of jurisdiction and failure to state a cause of action.
• On November 11, 1998, Judge Majaducon denied the motion to dismiss and granted a writ of preliminary injunction against the Committee.
• The Committee filed a petition for certiorari (G.R. No. 136760) with the Supreme Court, alleging grave abuse of discretion by Judge Majaducon.
• On January 13, 1999, The Philippine Star published a news report quoting portions of the Committee's petition, which stated Judge Majaducon was guilty of "gross ignorance of the rules and procedures."
• Judge Majaducon motu proprio initiated indirect contempt charges against Senator Pimentel (as Committee Chairman), the news reporter, and newspaper executives, alleging the report created an impression of his incompetence and violation of separation of powers.
• On April 15, 1999, Judge Majaducon found Senator Pimentel guilty of indirect contempt.
• Senator Pimentel filed a petition for review (G.R. No. 138378) with the Supreme Court challenging the contempt ruling.

• (G.R. No. 136760 - Senate Blue Ribbon Committee): The RTC lacks jurisdiction to restrain Congress from performing its constitutional function of conducting investigations in aid of legislation, based on the principle of separation of powers.
• (G.R. No. 136760 - Senate Blue Ribbon Committee): Flaviano's petition failed to state a cause of action as the legislative inquiry focused on the anomaly in the purchase, not the patenting/titling of the lot, which falls within the ambit of Senate Resolutions Nos. 157 and 160.
• (G.R. No. 136760 - Senate Blue Ribbon Committee): The RTC's issuance of the TRO ex-parte and the writ of preliminary injunction were invalid and unenforceable.
• (G.R. No. 136760 - Senate Blue Ribbon Committee): The ruling in Bengzon vs. Senate Blue Ribbon Committee was misapplied by the RTC.
• (G.R. No. 138378 - Senator Pimentel): The phrase "gross ignorance of the rules of procedure" or "gross ignorance of the law" used in the Committee's petition is not pejorative enough to constitute indirect contempt and is common usage in challenging lower court acts.
• (G.R. No. 138378 - Senator Pimentel): He had no participation in the publication of the Committee's petition by The Philippine Star, and such publication is a legitimate exercise of freedom of expression and the press.
• (G.R. No. 138378 - Senator Pimentel): By upholding the contempt charge, the respondent Judge preempted the Supreme Court in resolving the issues raised in G.R. No. 136760.

• (Atty. Nilo J. Flaviano in G.R. No. 136760): The trial court may properly intervene in congressional investigations pursuant to the power of judicial review.
• (Atty. Nilo J. Flaviano in G.R. No. 136760): He has a valid cause of action because the Committee's investigation would delve into the validity of the patenting and titling of Lot X, MR-1160-D, which is within judicial competence, and the matter is already subject to pending actions before another RTC and the Ombudsman.
• (Atty. Nilo J. Flaviano in G.R. No. 136760): The Bengzon v. Senate Blue Ribbon Committee case supports the issuance of a preliminary injunction when the right to self-incrimination is endangered, especially since an information was filed against him with the Sandiganbayan.
• (Judge Jose B. Majaducon in G.R. No. 138378): Senator Pimentel was guilty of indirect contempt for causing the publication of the Committee's petition, which was sub judice.
• (Judge Jose B. Majaducon in G.R. No. 138378): Senator Pimentel made derogatory remarks in the petition itself, affecting the honor and integrity of the judge and degrading the administration of justice.
• (Judge Jose B. Majaducon in G.R. No. 138378): Senator Pimentel made it appear that an administrative complaint was filed against the judge for gross ignorance of the law, constituting a malicious and false report obstructing justice.

• Whether respondent Judge Jose Majaducon committed grave abuse of discretion in denying the Senate Blue Ribbon Committee's motion to dismiss the petition for prohibition and in issuing the writ of preliminary injunction.
• Whether respondent Judge Jose Majaducon erred in convicting petitioner Senator Aquilino Q. Pimentel, Jr. of indirect contempt of court.

• Yes, respondent Judge Majaducon committed grave abuse of discretion in denying the motion to dismiss and issuing the writ of preliminary injunction because the RTC had no authority to prohibit the Senate Blue Ribbon Committee from requiring respondent Flaviano to appear and testify before it in an inquiry conducted in aid of legislation, pursuant to the principle of separation of powers and Article VI, Section 21 of the Constitution. The factual circumstances of Bengzon v. Senate Blue Ribbon Committee were different as in that case, no intended legislation was involved and the issue had already been pre-empted by a court.
• Yes, respondent Judge Majaducon erred in convicting petitioner Pimentel of indirect contempt. There was no evidence Pimentel caused the publication of the Committee's petition. The statement that the judge was "grossly ignorant of the rules of law and procedure" is not per se improper conduct tending to impede, obstruct, or degrade the administration of justice, as it is ordinarily found in administrative complaints or petitions seeking annulment of a judge's order where basic legal principles are disregarded, and there was no showing of malice. The power to punish for contempt must be exercised on the preservative, not vindictive, principle.

• Separation of Powers — This principle means that legislation belongs to Congress, execution to the Executive, and settlement of legal controversies to the Judiciary, with each branch prevented from invading the domain of the others. It was applied to rule that the RTC had no authority to prohibit the Senate Blue Ribbon Committee, a legislative body, from conducting its inquiry in aid of legislation.
• Power of Congress to Conduct Inquiries in Aid of Legislation (Article VI, Section 21, Constitution) — The Senate or the House of Representatives or any of its respective committees may conduct inquiries in aid of legislation in accordance with its duly published rules of procedure, and the rights of persons appearing in or affected by such inquiries shall be respected. This was the basis for the Senate Blue Ribbon Committee's authority to subpoena respondent Flaviano.
• Grave Abuse of Discretion — This exists when a respondent acts in a capricious, whimsical, arbitrary, or despotic manner in the exercise of judgment, as when the assailed order is bereft of any factual and legal justification. The Court found the RTC Judge's denial of the motion to dismiss and issuance of injunction to be without legal basis, thus constituting grave abuse of discretion.
• Indirect Contempt (Rule 71, Section 3(d) of the 1997 Rules of Civil Procedure) — This refers to any improper conduct tending, directly or indirectly, to impede, obstruct, or degrade the administration of justice, punishable after charge and hearing. The Court found Senator Pimentel not guilty as his actions (use of "gross ignorance" phrase in a petition) did not meet this standard, and he did not cause the allegedly contemptuous publication.
• Freedom of the Press — This right allows newspapers the "widest latitude of choice as to what items should see the light of day so long as they are relevant to a matter of public interest." This was invoked concerning the Philippine Star's publication of excerpts from the Committee's petition, noting Pimentel had no control over the newspaper's editorial decisions.
• Preservative Principle of Contempt Power — The power to declare a person in contempt of court must be exercised on the preservative, not vindictive principle, and on the corrective and not retaliatory idea of punishment. The Court cited this to emphasize that a judge should not be overly sensitive to criticism and that contempt power is a safeguard for judicial functions, not for judges as persons.

• "The principle of separation of powers essentially means that legislation belongs to Congress, execution to the Executive, and settlement of legal controversies to the Judiciary. Each is prevented from invading the domain of the others."
• "Hence, the Regional Trial Court of General Santos City, or any court for that matter, had no authority to prohibit the Committee from requiring respondent to appear and testify before it."
• "A judge, as a public servant, should not be so thin-skinned or sensitive as to feel hurt or offended if a citizen expresses an honest opinion about him which may not altogether be flattering to him... He should always bear in mind that the power of the court to punish for contempt should be exercised for purposes that are impersonal, because that power is intended as a safeguard not for the judges as persons but for the functions that they exercise."

• Bengzon v. Senate Blue Ribbon Committee (203 SCRA 767) — Referenced by respondent Flaviano to support RTC intervention. The Supreme Court distinguished it, stating that in Bengzon, no intended legislation was involved, the inquiry was more within judicial province, and the issue was already pre-empted by the Sandiganbayan, unlike the current case where there was a clear legislative purpose and no court had yet acquired jurisdiction over the specific anomaly being investigated by the Senate.
• Spouses Bacar v. Judge De Guzman, Jr. (338 Phil. 41) — Cited to support the argument that using the phrase "gross ignorance of the law" is not necessarily contemptuous. The Court noted that in Bacar, it was held that when the law is elementary, not knowing it or acting as if one does not know it constitutes gross ignorance of the law, implying the phrase has a recognized, albeit strong, descriptive meaning in legal discourse.
• Nazareno v. Barnes (220 Phil. 452) — Quoted for its articulation of the principle that judges should not be overly sensitive to criticism and that the contempt power should be exercised for impersonal purposes, safeguarding judicial functions rather than individual judges. This was applied to the contempt charge against Senator Pimentel.
• Ban Hua Flores v. Office of the Ombudsman (G.R. No. 136769, 17 September 2002) — Cited for the definition of grave abuse of discretion: acting in a capricious, whimsical, arbitrary or despotic manner, or when an order is bereft of factual and legal justification.
• Lopez v. Court of Appeals (145 Phil. 219) — Cited in relation to freedom of the press, stating that a publisher has the "widest latitude of choice as to what items should see the light of day so long as they are relevant to a matter of public interest."
• Oclarit v. Paderanga (350 SCRA 260) — Cited for the principle that the power to punish for contempt must be exercised on the preservative, not vindictive, principle.

• Article VI, Section 21 of the Constitution — This provision grants the Senate, the House of Representatives, or any of their respective committees the power to conduct inquiries in aid of legislation. It was the constitutional basis for the Senate Blue Ribbon Committee's investigation and its authority to issue subpoenas.
• Rule 71, Section 3(d) of the 1997 Rules of Civil Procedure — This rule defines indirect contempt, including "any improper conduct tending, directly or indirectly, to impede, obstruct, or degrade the administration of justice." It was the basis for the contempt charge against Senator Pimentel, which the Supreme Court found to be inapplicable to his actions.