In the classic case of Villavicencio vs. Lukban, G.R. No.

L-14639 March 25, 1919, the

Supreme Court of the Philippines upheld the right of Filipino citizens to freedom of domicile.

Outline

1. Facts
2. Issue
3. Ruling
4. Relevance

Facts

In 1918, the mayor of Manila, wanting to exterminate vice, had "houses of ill repute"
closed. He then had 170 prostitutes forcibly rounded up, put on a ship, and sent to Davao as
laborers. A writ of habeas corpus was filed against the mayor on behalf of those women. The
court granted the writ, but the mayor was not able to bring any of the women before the court on
the stipulated date.

Issue

Were the mayor's acts legal?

Ruling

The Supreme Court said that the mayor's acts were not legal. His intent of "exterminating
vice" was commendable, but there was no law saying that he could force Filipino citizens to
change their domicile from Manila to another place. The women, said the Court, although in a
sense "lepers of society" were still Filipino citizens and as such they were entitled to the
constitutional guarantees enjoyed by all other Filipino citizens. The right to freedom of domicile
was such a fundamental right that its suppression could be considered tantamount to slavery.]

Relevance

Direct contempt is that usually referred to as contempt in the face of the court (in facie
curiae), but this does not mean that such contempt must be committed while the judge is
presiding in open session in the courtroom. (Medina vs. Rivera, 66 Phil. 155).

Civil contempt is the failure to do something ordered to be done by a court or judge in a

civil case for the benefit of the opposing party therein. (Perkins vs. Director of Prisons, 58 Phil.
276).

Basic Notions Regarding Contempt

 Criminal contempt is conduct that is directed against the authority and dignity of a
judge acting judicially, as in unlawfully assailing or discrediting the authority and dignity of the
court or judge, or in doing a duly forbidden act. (Perkins vs. Director of Prisons, 58 Phil. 276).

The implied power to punish for contempt is coercive in nature. The power to punish
crimes is punitive in nature. The first is a vindication by the House of its own privileges. The
second is a proceeding brought by the State before the courts to punish offenders. (Lopez vs. De
los Reyes, 55 Phil. 180).

Contempt of court is a despising of the authority, justice, or dignity of the court; and he is
guilty of contempt whose conduct is such as tends to bring the authority and administration of
the law into disrespect or disregard. (Villavicencio vs. Lukban, 39 Phil. 809).

Contempt of court in general must be some act or conduct which tends to interfere with
the business of the court, by a refusal to obey some lawful order of the court, or some act of
disrespect to the dignity of the court which in some way tends to interfere with or hamper the
orderly proceedings of the court and thus to lessen the efficiency of the same. (In re: Jones, 9
Phil. 355).