FACTS:

• Incriminating acts of Eva Maravilla Ilustre: wrote threatening letters to the Justices of the
Supreme Court; filed an Affidavit-Complaint before the Tanodbayan that completely disregarded
facts, circumstances, and legal considerations; instigated the circulation of a false headline implying
graft and corruption charges against Justices

• Involvement of Atty. Wenceslao Laureta: likely wrote the threatening letters sent to the
Justices in Ilustre’s name; likely encouraged Ilustre’s pursuit of her Affidavit-Complaint with the
Tanodbayan and her disparaging remarks regarding the Justices in her letters and comments to the
media; was responsible for all the acts of his clients

ISSUE:

WoN Ilustre’s and Laureta’s actions violate the principle of separation of powers.

HELD:

YES. (Ratio: In their persistence to overturn detrimental decisions, their threats of

“exposing” the supposed corruption of the SC to the media, and their unfounded complaint to the
Tanodbayan, Ilustre and Laureta attempted to subject the judiciary to the executive, which is
unjustifiable under separation of powers.)

o Independence of the judiciary is the indispensable means for enforcing the supremacy of
the Constitution

o Reciprocity: The decisions of the SC, whether en banc or division, are as credible as the
enrolled bills of the legislature, and therefore beyond investigation or inquiry; applicable also the the
executive