A distinction between in-court
contempts, which disrupt court proceedings and for which a hearing and
formal presentation of evidence are dispensed with, and out-of-court contempts,
which require normal adversary procedures, is drawn for the purpose of
prescribing what procedures must attend the exercise of a court’s authority to
deal with contempt. The distinction does not limit the ability of courts to
initiate contempt prosecutions to the summary punishment of in-court contempts that interfere with
the judicial process. (LORENZO SHIPPING
CORPORATION VS. DISTRIBUTION BUTTON
MANAGEMENT ASSOCIATION OF THE PHILIPPINES [2011]).
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