Borromeo Digest

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IN RE JOAQUIN BORROMEO

-A.M. No. 93-7-696-0. February 21, 1995

FACTS

On the 12th of February 1995, the Supreme Court has decided to issue a decision in relation to
the mishaps of Joaquin T. Borromeo, a Cebuano who’s “come to posses superficial awareness
of a few substantive legal principles and procedural rules”, but is not registered to the Integrated
Bar of the Philippines, and, most importanty, not a lawyer.

For almost 16 years, he has been instituting and prosecuting legal proceeding in different
courts, and has the balls to represent himself in numerous original and review proceedings,
which, expectedly, have been disastrous. He also circulated scandalous and defamatory
statements against courts, judges, their employees, and his opponents in the legal arena.

He also filed petition for certiorari and grave abuse of discretion amounting to lack or excess of
jurisdiction to Court of Appeals (CA). The aforementioned petitions should only be filed in
Supreme Court, which has the power to review cases.

In total, he filed 50 cases, all of which were lawyered by himself. 

The pseudo-lawyer spreaded defamatory and libelous flyers against the Integrated Bar of the
Philippines-Cebu Chapter and the Regional Trial Court judges of the province, and to the CA
and SC justices. This prompted the filing of an action of contempt against him for his ignorant
battling with the courts for “abuse of and interference with judicial rules and processes, gross
disrespect to courts and judges and improper conduct directly impeding, obstructing, and
degrading the administration of justice”.

The Cebu City Chapter of the Integrated Bar of the Philippines (IBP) addressed a letter to the
Supreme Court quoting Borromeo's defamatory remarks against the SC and the judiciary, and
strongly urging the SC to impose the attendant sanctions.

The matter was then docketed as a proceeding for contempt. Borromeo contends, inter alia, that
it was necessary that the Chief Justice and other members of the SC should inhibit "since they
cannot be the accused and judge at the same time."

Issue: WoN Joaquin Borromeo is guilty of contempt?

Upon the indubitable facts on record, there can scarcely be any doubt of Borromeo's guilt of
contempt, for abuse of and interference with judicial rules and processes, gross disrespect to
courts and judges and improper conduct directly impeding, obstructing and degrading the
administration of justice.
Superficial was his other contention that in making the allegations claimed to be contumacious,
he "was exercising his rights of freedom of speech, of expression, and to petition the
government for redress of grievances as guaranteed by the Constitution (Section 4, Article III)
and in accordance with the [Constitution’s provisions on the] accountability of public officials."
The constitutional rights invoked by him afford no justification for repetitious litigation of the
same causes and issues, for insulting lawyers, judges, court employees; and other persons, for
abusing the processes and rules of the courts, wasting their time, and bringing them into
disrepute and disrespect.
He was sentenced to serve a term for 10 days and a fine of Php 1,000. He was also warned that
serious sanctions will be charged against him if he repeats the similar offenses which he is
found guilty or any similar offense against courts, judges or court employees.

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