- Petitioner
- Finnick
- Respondent
- Peterson
- Citation
- G.R. No. 3174
- Court
- Supreme Court
- Decided
- April 20, 1906
Whether a court has authority to issue subpoena duces tecum requiring production of personal property (jewelry) and whether contempt for disobedience…
Summary
This landmark 1906 case involved a habeas corpus petition challenging detention for contempt of court. Finnick was subpoenaed to testify and produce jewelry as evidence in a criminal estafa case but refused to bring the jewelry, claiming the court lacked authority. The trial judge ordered his imprisonment for contempt and denied appeal. The Supreme Court affirmed his discharge, establishing two important precedents: (1) courts have authority under Code of Civil Procedure section 402 and Penal Code Article 120 to compel production of personal property via subpoena duces tecum when needed as evidence in criminal cases involving restitution; and (2) contempt committed through disobedience of a subpoena, rather than misbehavior in the court's presence, requires procedural due process including hearing before punishment. The case clarified the scope of subpoena power and contempt procedures in early Philippine jurisprudence.