Case #1

Title of the Case:

Samson B. Sindon vs. Presiding Judge Raphiel F. Alzate
Citation: A.M. No. RTJ-20-2576 (Formerly OCA IPI No. 18-4864-RTJ), January 29, 2020

Ponente:
Associate Justice LAZARO-JAVIER

Doctrine:
A judge must exhibit impartiality and avoid involvement in cases where they or their close family
members have a direct interest, ensuring the integrity and impartiality of the judiciary. This principle is
crucial to maintaining public confidence in the judicial system.

Facts:
Complainant Samson B. Sindon alleged that Judge Raphiel F. Alzate and Clerk of Court Atty. Janice
Siganay Querrer, of the Regional Trial Court, Branch 1, Bangued, Abra, conspired to unduly favor Judge
Alzate’s wife by granting her a notarial commission and subsequently failed to provide Sindon a copy of
the order related to this grant.

Sindon’s request, filed through his counsel, was allegedly denied and the record suppressed.

Judge Alzate contested the allegations, suggesting the complaint was motivated by external political
pressures and clarified that the notarial commission was granted in compliance with legal requirements.

Atty. Querrer corroborated Judge Alzate's response, detailing the procedural steps taken to address
Sindon's request. Sindon later sought to withdraw his complaint, claiming he was misled into filing it.

Issue/s:
 Whether or not Sindon's motion to withdraw affects the court's jurisdiction over the administrative
case.
 Whether or not Judge Alzate and Atty. Querrer can be held administratively liable for their alleged
inaction and supposed conspiracy to benefit Alzate's wife.
 Whether or not Judge Alzate is liable for failing to recuse himself from his wife's application for
notarial commission.

Ruling:
The Court held that Sindon's withdrawal of the complaint does not affect its jurisdiction, emphasizing
that administrative proceedings serve to uphold judicial integrity and discipline, independent of the
complainant's interests.

The charges against Atty. Querrer were dismissed for lack of merit, and both she and Judge Alzate were
found not liable for the alleged inaction on Sindon's request, which was acted upon within the
prescribed period.

Judge Alzate was found guilty of violating Section 1, Rule 137 of the Rules of Court for not recusing
himself from his wife's notarial commission application. This action breached the standards of judicial
conduct by failing to avoid impropriety or the appearance of impropriety in their activities.
Disposition:
Judge Raphiel F. Alzate was reprimanded with a warning against the repetition of similar actions, while
the charges against Atty. Janice Siganay-Querrer were dismissed.

Case #2

Title of the Case:

Office of the Court Administrator vs. Presiding Judge Joselito C. Villarosa

Citation: A.M. No. RTJ-20-2578 (Formerly A.M. No. 19-11-268-RTC), January 28, 2020

Ponente:
Per Curiam

Doctrine:
Gross ignorance of the law reflects a judge's disregard for basic legal principles and settled
jurisprudence, compromising the integrity and efficiency of the judiciary. When a judge's actions are
found not just erroneous but motivated by bad faith, dishonesty, or a disregard for procedural rules, it
constitutes gross ignorance of the law. Judges are expected to have a thorough understanding of the law
and to apply it with competence and integrity. Ignorance of the law, especially when it results in
injustice, is unacceptable and warrants administrative sanctions to uphold the judiciary's credibility and
ensure the proper administration of justice.

This case underscores the responsibility of judges to adhere strictly to legal and procedural standards,
the importance of judicial competence, and the necessity of maintaining the integrity of the judiciary
through accountability for actions that deviate from established legal norms and directives.

Facts:
An article by Ramon Tulfo in the Philippine Daily Inquirer on July 7, 2015, alleged misconduct among
three Makati judges, including Judge Joselito C. Villarosa of Branch 66, RTC, Makati City. Tulfo accused
Judge Villarosa of favoring affluent litigants in commercial cases, being part of a syndicate of Makati
judges making decisions based on bribes rather than merits, and highlighted a history of reversed
decisions by the Court of Appeals. Specific allegations included issuing a TRO against the DOTC for a
P3.77 billion train car procurement at the behest of a losing bidder. The Office of the Court Administrator
(OCA) initiated an investigation, which was conducted alongside a judicial audit of Judge Villarosa's
court. The audit found several violations, including failure to transfer commercial cases to the designated
Special Commercial Court and the issuance of a TRO beyond the 20-day limit.

Judge Villarosa provided explanations for each of the audit's findings, which included justifications for
delays and procedural missteps, claiming adherence to an agreement with another judge and the
practical challenges of case pagination. He also contested the characterization of his actions as violations
of Supreme Court directives and the Rules of Court.

Issue:
Whether or not Judge Villarosa is guilty of gross ignorance of the law and of violation of Supreme Court
rules, directives, and circulars.

Ruling:
The Supreme Court adopted the OCA's findings, concluding that Judge Villarosa was guilty of four counts
of gross ignorance of the law and of violating a Supreme Court directive. The Court highlighted Judge
Villarosa's deliberate non-compliance with directives, procedural mismanagement, and improper
issuance of a TRO against DOTC in violation of Republic Act No. 8975. For these violations, the Court
ordered the forfeiture of all Judge Villarosa's retirement benefits except accrued leave credits, imposed a
fine totaling P140,000 to be deducted from his leave credits, and disqualified him from reemployment in
any government position.

Disposition:
Judge Joselito C. Villarosa was found guilty of gross ignorance of the law and violation of Supreme Court
directives, resulting in the forfeiture of all retirement benefits (except accrued leave credits), a fine of
P140,000 deducted from his leave credits, and disqualification from future government employment.

Case #3

Title of the Case:

Philippine National Construction Corporation vs. Hon. Jesus B. Mupas, Presiding Judge Branch 112,
Regional Trial Court, Pasay City

Citation:
A.M. No. RTJ-20-2593 (Formerly: OCA IPI No. 20-5067-RTJ), November 10, 2020

Ponente:
Per Curiam

Doctrine:
Gross ignorance of the law manifests when a judge disregards basic rules and settled jurisprudence,
demonstrating a failure to apply the law properly in good faith. Judges are expected to possess a deep
understanding of legal principles and apply them judiciously to uphold the integrity of the judiciary and
maintain public confidence in the legal system. A judge's failure to observe basic legal rules not only
betrays the public trust but also undermines the administration of justice, warranting disciplinary action
to preserve the judiciary's credibility and ensure fair and just legal proceedings.

Facts:
The Philippine National Construction Corporation (PNCC) reported to the Supreme Court the alleged
improper issuance of a Temporary Restraining Order (TRO) and Writ of Preliminary Injunction (WPI) by
Hon. Jesus B. Mupas, relating to lease disputes over the Financial Center Area (FCA) owned by PNCC.
Despite the lease contracts' expiration, lessees refused to vacate, prompting PNCC to file ejectment
cases. Judge Mupas issued injunctive reliefs favoring the lessees, which PNCC contested as irregular and
contrary to procedural norms.

Issue:
Whether or not Judge Mupas is guilty of gross ignorance of the law for issuing injunctive reliefs in
violation of procedural rules and jurisprudence.

Ruling:
The Supreme Court found Judge Mupas guilty of three counts of gross ignorance of the law for his
actions in issuing the injunctive reliefs. The Court highlighted that Judge Mupas disregarded basic
procedural rules and jurisprudence, failing to demonstrate the requisite legal acumen and impartiality
expected of a judge. The issuance of injunctive reliefs without proper legal basis and in contravention of
established procedures was deemed inexcusable, constituting gross ignorance of the law.

Disposition:
Judge Jesus B. Mupas was fined a total of P125,000 for the first two counts of gross ignorance of the law
and dismissed from service for the third count. His retirement benefits were forfeited, except for accrued
leave credits, and he was perpetually disqualified from re-employment in any government agency or
instrumentality, including government-owned and controlled corporations. This decision underscores the
judiciary's commitment to uphold the highest standards of legal knowledge, integrity, and justice among
its members.

Case #4

Title of the Case:

Provincial Prosecutor Jorge D. Baculi vs. Judge Medel Arnaldo B. Belen

Citation:
A.M. No. RTJ-11-2286 (formerly OCA IPI No. 09-3291-RTJ), February 12, 2020

Ponente:
LAZARO-JAVIER, J.

Doctrine:
Members of the judiciary are expected to conduct themselves with integrity, honesty, and respect for
the judicial office, embodying principles that maintain public confidence in the judiciary. Dishonesty,
defined as a disposition to lie, cheat, deceive, or defraud; untrustworthiness; and lack of integrity, is
incompatible with the role of a judge. A judge's actions, both in their official duties and personal
conduct, must be free from any appearance of impropriety, upholding the highest standards of behavior
expected of public servants entrusted with the administration of justice.

Facts:
Provincial Prosecutor Jorge D. Baculi filed a complaint against Judge Medel Arnaldo B. Belen of the
Regional Trial Court, Branch 36, Calamba City, Laguna, for various violations including receipt of
honoraria from the local government during his suspension period. The Supreme Court had previously
suspended Judge Belen for six months without salary or benefits for gross ignorance of the law. Despite
this, Judge Belen received his monthly allowance from the Office of the City Treasurer of Calamba City
for the months of June and July 2009. Baculi argued that this act was contrary to law and demonstrated
a disregard for the Supreme Court's ruling. Judge Belen responded with a general denial of the
allegations.
The Office of the Court Administrator (OCA) recommended that the complaints be re-docketed as a
regular administrative matter and that Judge Belen be found guilty of dishonesty and dismissed from
service with forfeiture of his retirement and all other benefits, except accrued leave credits.

Issue:
Whether or not Judge Belen is administratively liable for receiving allowances from the local government
during the period of his suspension.

Ruling:
The Supreme Court found Judge Belen guilty of dishonesty for receiving his monthly allowances during
the period of his suspension, which was in direct contravention of the Court's decision. His actions
demonstrated a lack of integrity and disrespect for the Court's authority. Although Judge Belen had
already been dismissed from service in a prior case, the Court imposed a fine of Forty Thousand Pesos
(Php40,000.00), to be deducted from his accrued leave credits, and directed him to reimburse the local
government units the amount of Sixteen Thousand Pesos (Php16,000.00) he unlawfully received. This
decision underscores the judiciary's commitment to upholding the highest ethical standards and
ensuring accountability for actions that undermine the integrity of the judicial system.

Disposition:
Judge Medel Arnaldo B. Belen is found guilty of dishonesty and is ordered to pay a fine of Php40,000.00,
to be deducted from his accrued leave credits. He is also directed to reimburse the local government
units the amount of Php16,000.00, which he received unlawfully during his suspension period.

Case #5

Title of the Case:

Re: Anonymous Complaint Against Judge Laarni N. Dajao, Presiding Judge, Regional Trial Court, Branch
27, Siocon, Zamboanga del Norte

Citation:
A.M. No. RTJ-16-2456, March 02, 2020

Ponente:
DELOS SANTOS, J.

Doctrine:
The New Code of Judicial Conduct mandates that judges shall avoid impropriety and the appearance of
impropriety in all of their activities, upholding the dignity of the judicial office at all times. Judges are
expected to exhibit more than just a cursory acquaintance with statutes and procedural rules, and to
apply them properly in all good faith. Vulgar and unbecoming conduct erodes public confidence in the
judiciary, and judges must conduct themselves in a manner that preserves the integrity and dignity of
their office, avoiding any actions or language that may bring disrepute to the judiciary.

Facts:
An anonymous letter-complaint dated January 15, 2014, accused Judge Laarni N. Dajao of exhibiting
unprofessional conduct by using vulgar language in hearings and official documents. Specifically, the
complaint highlighted an Order dated November 27, 2013, in Criminal Case Nos. 2013-08-05 (1049),
2013-08-06 (1050), and 2013-08-07 (1051), where Judge Dajao used derogatory terms and insinuated a
sexual relationship between the accused and himself. Additionally, the complaint noted Judge Dajao's
practice of appending "Dr." and "Ph.D." to his name in official documents, suggesting a lack of humility.
Judge Dajao defended himself by stating that the complaint aimed to malign him and that the criminal
cases mentioned were dismissed without prejudice. He also mentioned accepting an apology from the
PDEA Regional Director for the operatives involved in the case.

Issue:
Whether or not Judge Laarni N. Dajao is administratively liable for vulgar and unbecoming conduct.

Ruling:
The Supreme Court adopted the findings and recommendation of the Office of the Court Administrator
(OCA), finding Judge Dajao administratively liable for vulgar and unbecoming conduct. The Court
emphasized that judges should conduct themselves in a manner consistent with the dignity of the
judicial office, refraining from using intemperate language and making unseemly insinuations in their
rulings. Furthermore, the Court disapproved of Judge Dajao's practice of including academic titles in his
official designation, considering it as self-promotion and contrary to the expected humility of a judge.
Consequently, Judge Dajao was fined Five Thousand Pesos (P5,000.00), with a severe warning that a
repetition of similar acts would be dealt with more severely.

Disposition:
Respondent Judge Laarni N. Dajao is found guilty of vulgar and unbecoming conduct and is fined Five
Thousand Pesos (P5,000.00), with a stern warning that a repetition of the same or similar acts in the
future shall be dealt with more severely.

Case #6

Title of the Case:

Re: Result of the Judicial Audit Conducted in Branch 49, Regional Trial Court, Puerto Princesa City,
Palawan

Citation:
A.M. No. 19-12-293-RTC, June 30, 2020

Ponente:
DELOS SANTOS, J.

Doctrine:
The Constitution mandates lower court judges to decide a case within the reglementary period of ninety
(90) days. The Code of Judicial Conduct under Rule 3.05 of Canon 3 directs judges to administer justice
without delay and dispose of the court's business promptly within the period prescribed by law. Failure
to resolve cases submitted for decision within the period fixed by law constitutes a serious violation of
the constitutional right of the parties to a speedy disposition of their cases. Judges must act with
efficiency and probity, and their failure to decide cases within the prescribed period, without a valid
reason, constitutes gross inefficiency.

Facts:
A judicial audit in the Regional Trial Court (RTC) of Puerto Princesa City, Palawan, Branch 49, presided
over by Judge Leopoldo Mario P. Legazpi, revealed significant delays and inaction in case management.
The audit found 88 cases submitted for decision, 79 of which were beyond the reglementary period; 51
cases with pending incidents submitted for resolution, 40 of which were overdue; 49 cases with no
further action or setting for a considerable length of time; 3 cases with no initial action; and 24 cases due
for archiving. Judge Legazpi failed to decide or resolve these cases within the prescribed period and did
not request an extension of time. He attributed the backlog to an inherited caseload, heavy workload,
court personnel vacancies, and health issues. Despite submitting his resignation effective March 15,
2015, the Office of the Court Administrator (OCA) recommended imposing a fine for gross inefficiency.

Issue:
Whether or not Judge Leopoldo Mario P. Legazpi should be held administratively liable for gross
inefficiency due to his failure to decide cases and resolve pending incidents within the reglementary
period.

Ruling:
The Supreme Court found Judge Legazpi guilty of gross inefficiency for his undue delay in rendering
decisions or orders. The Court emphasized the imperative need for judges to decide cases and resolve
pending matters within the prescribed period to uphold the constitutional right to a speedy trial and
maintain public confidence in the judiciary. Despite understanding the challenges faced by Judge Legazpi,
including a heavy caseload and staffing issues, the Court noted that he could have requested a
reasonable extension to decide the cases, but failed to do so. Consequently, the Court imposed a fine of
Fifty Thousand Pesos (P50,000.00), to be deducted from Judge Legazpi's accrued leave credits,
recognizing his resignation but underscoring the importance of judicial efficiency and accountability.

Disposition:
Judge Leopoldo Mario P. Legazpi is fined Fifty Thousand Pesos (P50,000.00) for gross inefficiency, with
the amount to be deducted from his accrued leave credits, underscoring the judiciary's commitment to
timely justice delivery and the efficient management of caseloads.

Case #7

Title of the Case:

Office of the Court Administrator v. Hon. Marilyn B. Lagura-Yap, Former Presiding Judge, Branch 28,
Regional Trial Court, Mandaue City, Cebu (Now Associate Justice of the Court of Appeals)

Citation:
A.M. No. RTJ-12-2337 (Formerly A.M. No. 12-10-224-RTC), June 23, 2020

Ponente:
PER CURIAM
Doctrine:
The Constitution mandates the prompt disposition of cases, requiring judges to decide or resolve cases
within specific periods to maintain the integrity and efficiency of the judiciary. Failure to comply with
these mandates constitutes gross inefficiency. Additionally, honesty and integrity in fulfilling the
requirements of applications for judicial positions, including the accurate disclosure of caseloads, are
fundamental to the administration of justice. Administrative sanctions may be imposed for failure to
observe these standards.

Facts:
This administrative case involves Hon. Marilyn B. Lagura-Yap, in her capacity as then Presiding Judge of
Branch 28, RTC, Mandaue City, Cebu, and later as Associate Justice of the Court of Appeals. She faced
charges of gross inefficiency and incompetence for failing to decide 133 criminal cases and 35 civil cases
within the reglementary period, and for dishonesty for her failure to disclose her caseload in her
application for the position of Associate Justice of the Court of Appeals and for inaccurately reflecting
the actual number of cases submitted for decision in the Monthly Report of Cases to the OCA. Despite
reminders and the requirement of a certification manifesting that she had disposed of cases assigned to
her, she assumed her new responsibilities without resolving all cases. The OCA recommended a fine of
P100,000 for gross inefficiency and an admonition for greater circumspection in her duties.

Issue:
Whether or not Hon. Marilyn B. Lagura-Yap should be held administratively liable for gross inefficiency
for failing to decide cases within the reglementary period and for dishonesty in her application for the
position of Associate Justice of the Court of Appeals.

Ruling:
The Court found Hon. Marilyn B. Lagura-Yap guilty of gross inefficiency for failing to decide 160 cases
within the reglementary period and to submit the required certification of caseload before the Judicial
and Bar Council. She was fined an amount equivalent to one (1) year of her current salary and
admonished to be more diligent in the performance of her duties as a dispenser of justice. The Court
emphasized the importance of prompt case disposition and honesty in judicial applications to uphold the
integrity and efficiency of the judiciary. The decision underscores the judiciary's commitment to ensuring
that its members adhere to the highest standards of integrity, efficiency, and accountability.

Disposition:
Hon. Marilyn B. Lagura-Yap is fined an amount equivalent to one (1) year of her current salary for gross
inefficiency and failure to submit the required certification of caseload, payable within thirty (30) days
from receipt of notice. She is further admonished to demonstrate greater diligence and integrity in her
judicial functions, especially as an Associate Justice of the Court of Appeals. The decision is immediately
executory.

Case #8

Title of the Case:

Office of the Court Administrator v. Hon. Fernando F. Flor, Jr., Presiding Judge, Branch 28, Regional Trial
Court, Bayombong, Nueva Vizcaya
Citation:
A.M. No. RTJ-17-2503, July 28, 2020

Ponente:
PER CURIAM

Doctrine:
Judges are duty-bound to know and understand the law. Their failure to adhere to elementary legal
rules, especially in the grant of bail applications for non-bailable offenses, constitutes gross ignorance of
the law, warranting administrative sanctions. A judge's role is pivotal in maintaining the integrity and
competence of the judiciary; thus, a high standard of judicial conduct is required to preserve the public's
confidence in the judicial system. Gross ignorance of the law by a judge undermines the administration
of justice and erodes public trust in the judiciary.

Facts:
Hon. Fernando F. Flor, Jr., was charged with gross ignorance of the law for improperly granting bail in
several criminal cases involving the illegal sale of dangerous drugs, which are non-bailable offenses
under Philippine law. The Office of the Court Administrator (OCA) received a complaint from Atty. Jona
Gay Pua-Mendoza, Clerk of Court, highlighting instances where Judge Flor granted bail without the
requisite summary of prosecution evidence or without conducting a hearing on the motion to reduce
bail. Judge Flor admitted to issuing the orders without the summary of prosecution evidence and
pleaded for compassion due to his application for early retirement. The OCA recommended a fine of
P50,000.00 after finding Judge Flor guilty of gross ignorance of the law, noting his previous
administrative sanction for issuing a warrant of arrest while knowing the private complainant was his
wife.

Issue:
Whether or not Hon. Fernando F. Flor, Jr. should be held administratively liable for gross ignorance of the
law for granting bail in non-bailable offenses without conducting the requisite hearings and without
providing a summary of the prosecution evidence.

Ruling:
The Supreme Court found Judge Flor liable for gross ignorance of the law due to his failure to adhere to
procedural requirements in granting bail for non-bailable offenses. The Court underscored that bail
cannot be granted without a prior hearing in cases punishable by reclusion perpetua or life
imprisonment, as the grant or denial of bail hinges on whether the evidence of guilt is strong. The Court
highlighted that Judge Flor's actions disregarded the procedural necessity of hearings, especially in
capital offenses where utmost diligence is required. The resolutions issued by Judge Flor in several
criminal cases lacked a brief summary of evidence adduced by the prosecution, which is necessary to
determine the basis for granting bail. Considering Judge Flor's repeated infractions and refusal to correct
his ways despite a previous warning, the Court imposed the supreme penalty of dismissal from service,
with forfeiture of retirement benefits except leave credits, and with prejudice to re-employment in any
branch or instrumentality of the government. This decision serves as a stern reminder of the judiciary's
expectations of its members to maintain competence, integrity, and independence in the administration
of justice.

Disposition:
Judge Fernando F. Flor, Jr. is dismissed from the service with forfeiture of retirement benefits, except
leave credits, and with prejudice to re-employment in any branch or instrumentality of the government,
including government-owned and controlled corporations.

Case #9

Title of the Case:

Hortencia R. Cayabyab vs. Presiding Judge Irineo P. Pangilinan, Jr., Regional Trial Court, Branch 58,
Angeles City, Pampanga

Citation:
A.M. No. RTJ-20-2584 (formerly OCA IPI No. 18-4841-RTJ), July 28, 2020

Ponente:
Justice Caguioa

Doctrine:
A judge's undue delay in rendering a decision undermines the people's faith and confidence in the
judiciary and contravenes the constitutional mandate for the speedy disposition of cases. The delivery of
judicial decisions within the periods set by law is not only an obligation imposed by the Constitution but
also a requirement that ensures the rights of all parties are protected. Administrative sanctions may be
imposed for failure to comply, reflecting the judiciary's commitment to discipline and efficiency.

Facts:
Hortencia R. Cayabyab filed an administrative complaint against Judge Irineo P. Pangilinan, Jr. for undue
delay in rendering a decision, knowingly rendering an unjust judgment, and gross ignorance of the law in
relation to Criminal Case No. 10-5530, "People of the Philippines v. Maria Melissa Cayabyab y Robles" for
Perjury. Despite the case being submitted for decision, the promulgation was delayed and eventually led
to the acquittal of the accused. Cayabyab argued that the acquittal demonstrated gross ignorance of the
law, as the accused was found to have deliberately made false statements. Additionally, Cayabyab raised
concerns about potential bias due to a personal connection between the judge and the accused.

Issue:
Whether or not Judge Irineo P. Pangilinan, Jr. should be held administratively liable for undue delay in
rendering a decision, knowingly rendering an unjust judgment, and gross ignorance of the law.

Ruling:
The Supreme Court agreed with the findings of the Office of the Court Administrator (OCA), with a
modification on the penalty imposed. Judge Pangilinan was found guilty of undue delay in rendering a
decision, violating the constitutional mandate for the speedy resolution of cases. A fine of P10,000.00
was imposed as a penalty. However, the charges of knowingly rendering an unjust judgment and gross
ignorance of the law were dismissed for lack of merit. The Court emphasized that administrative
complaints cannot proceed alongside judicial remedies and highlighted the importance of final appellate
declarations before determining administrative liability. The decision underscored that errors in
judgment or differences in legal interpretation do not necessarily constitute gross ignorance of the law
or render a judgment unjust, absent evidence of bad faith, dishonesty, or malicious intent.
Disposition:
Judge Irineo P. Pangilinan, Jr. was found guilty of undue delay in rendering a decision and fined
P10,000.00, with a warning that repetition of the same or similar act would be dealt with more severely.
The other charges against him were dismissed for lack of merit.

Case #10

Title of the Case:

Sharon Flores-Concepcion vs. Judge Liberty O. Castaneda, Regional Trial Court, Branch 67, Paniqui, Tarlac

Citation:
A.M. No. RTJ-15-2438 [Formerly OCA I.P.I. No. 11-3681-RTJ], September 02, 2020

Ponente:
Justice Leonen

Doctrine:
The death of a respondent in an administrative case renders the case moot and dismisses the complaint
due to the impossibility of imposing penalties and the violation of the deceased respondent's right to
due process. Continuing with the administrative proceedings against a deceased individual would
unjustly affect the heirs by imposing a monetary penalty on the decedent's estate, which they stand to
inherit. The administration of justice must be tempered with the recognition of the finality of death and
the limitations it imposes on judicial proceedings.

Facts:
Sharon Flores-Concepcion filed an administrative complaint against Judge Liberty O. Castaneda for
nullifying her marriage without her knowledge. Concepcion discovered the nullification upon receiving a
decision dated July 30, 2010, which declared her marriage void ab initio, despite not being aware of any
petition filed by her husband and neither party being residents of Paniqui, where the case was filed.
Upon investigation, it was revealed that no hearing had been conducted for the case. Judge Castaneda
failed to comply with directives to comment on the complaint. She was dismissed from service in 2012
for unrelated charges before the reevaluation of Concepcion's complaint was ordered by the Court. The
Office of the Court Administrator recommended that Judge Castaneda be found guilty of gross ignorance
of the law and disbarred for violating the Code of Professional Responsibility. However, Judge Castaneda
passed away on April 10, 2018, from acute respiratory failure, before the resolution of the complaint.

Issue:
Whether or not the death of respondent Judge Liberty O. Castaneda warrants the dismissal of the
Administrative Complaint lodged against her.

Ruling:
The Supreme Court dismissed the administrative complaint against Judge Liberty O. Castaneda due to
her death during the pendency of the case. The Court reasoned that proceeding with the case would
violate the fundamental right to due process, as the deceased cannot defend herself or participate in the
proceedings. Additionally, any monetary penalty imposed on the deceased's estate would unfairly
burden her heirs, who are not responsible for the respondent's actions. The Court emphasized that the
objective of administrative proceedings is not to punish the individual but to uphold the integrity and
accountability of the judiciary, and with the respondent's death, there is no longer a subject for such
accountability. The dismissal is in line with the principle that administrative cases seek to protect the
public and the judiciary from misconduct, which cannot be achieved posthumously.

Disposition:
The Supreme Court dismissed the administrative complaint against Judge Liberty O. Castaneda due to
her death, recognizing the impossibility of continuing the proceedings and upholding the principles of
justice and due process.

Case #11

Title of the Case:

Presiding Judge Marigel S. Dagani-Hugo, Regional Trial Court, Branch 3, Butuan City, Agusan Del Norte,
Complainant, vs. Judge Dennis B. Castilla, Municipal Trial Court in Cities, Branch 1, Butuan City, Agusan
Del Norte, Respondent.

Citation:
OCA IPI No. 20-3093-MTJ, October 14, 2020

Ponente:
Justice Delos Santos

Doctrine:
In administrative proceedings, the complainant bears the burden of proving the allegations in their
complaints by substantial evidence. If they fail to satisfactorily show the facts upon which their claims
are based, the respondent is not obliged to prove their exception or defense. The evidence against the
respondent should be competent and derived from direct knowledge.

Facts:
The case against Judge Dennis B. Castilla originated from counter-charges filed by Judge Marigel S.
Dagani-Hugo in an administrative matter. Judge Castilla had initially charged Judge Hugo with Ignorance
of the Law and Conduct Prejudicial to the Best Interest of Service, alleging biases in case dismissals,
involvement in a parking space re-assignment issue, and connivance in filing a VAWC case, among
others. Judge Hugo denied these allegations and counter-charged Judge Castilla with disrespect towards
the hierarchy of courts, insulting colleagues, not following office memoranda, and having an illicit affair
with a PAO lawyer, supported by various documents and an affidavit.

Issue:
Whether or not Judge Dennis B. Castilla is administratively liable for the counter-charges filed against
him.

Ruling:
The Supreme Court dismissed the complaint against Judge Dennis B. Castilla for lack of factual and legal
merit. The Court found that the evidence provided by Judge Hugo did not meet the required quantum of
evidence to establish administrative liability. Specifically, the allegations of disrespect to higher courts,
insulting colleagues, and involvement in an illicit affair were not supported by competent evidence
derived from direct knowledge. The transcript of text messages alleged to show an affair with a PAO
lawyer was not properly verified or authenticated. Additionally, Judge Castilla's acknowledgment and
explanation regarding his absences from flag ceremonies were deemed satisfactory by the Court. Thus,
Judge Hugo failed to discharge the burden of proof required in administrative proceedings.

Disposition:
The Supreme Court dismissed the administrative complaint against Judge Dennis B. Castilla for lack of
factual and legal merit, underscoring the principle that the complainant must prove their case with
substantial evidence in administrative proceedings.

Case #12

Title of the Case:

Philippine Deposit Insurance Corporation vs. Judge Winlove M. Dumayas, Presiding Judge of the Regional
Trial Court of Makati City, Branch 59; and Francis R. Yuseco, Jr. vs. Honorable Winlove M. Dumayas,
Presiding Judge, Branch 59, Regional Trial Court, Makati City

Citation:
A.M. No. RTJ-21-015 [Formerly OCA IPI No. 13-4162-RTJ] and [OCA IPI No. 15-4381-RTJ], November 17,
2020

Ponente:
Justice Zalameda

Doctrine:
Under Section 5(g) of Rule 135, every court shall have the inherent power to amend and control its
processes and orders, so as to make them conformable to law and justice. This power includes the right
to reverse itself, especially when, in its honest opinion, it has committed an error or mistake in judgment,
and that to adhere to its decision will cause injustice to a party-litigant. However, when a judge's failure
to interpret the law or to properly appreciate the evidence presented does not necessarily render him
administratively liable. Only judicial errors tainted with fraud, dishonesty, gross ignorance, bad faith, or
deliberate intent to do an injustice will be administratively sanctioned.

Facts:
The case involves two administrative complaints filed against Judge Winlove M. Dumayas for gross
ignorance of the law in connection with the liquidation of Unitrust Development Bank (UDB). The
Monetary Board had placed UDB under the receivership of the Philippine Deposit Insurance Corporation
(PDIC), leading to liquidation proceedings where Judge Dumayas issued orders that demonstrated a
vacillation on the issue of UDB's liquidation. His orders were inconsistent, showing a lack of
understanding of relevant laws and jurisprudence, particularly the authority of the Monetary Board to
close banks and the limited role of the liquidation court in such proceedings.

Issue:
Whether or not Judge Winlove M. Dumayas exhibited gross ignorance of the law in issuing orders related
to the liquidation of UDB, warranting administrative sanctions.

Ruling:
The Supreme Court found Judge Dumayas guilty of gross ignorance of the law or procedure in A.M. No.
RTJ-21-015 and ordered him to pay a fine of Forty Thousand Pesos (Php40,000.00), in view of his
previous dismissal from the service. The Court highlighted Judge Dumayas' failure to adhere to the basic
legal principles and his inconsistent rulings, which not only showed a disregard for the law but also
undermined public confidence in the judiciary. In OCA IPI No. 15-4381-RTJ, filed by Yuseco, the complaint
was dismissed for lack of merit, as Judge Dumayas acted within his authority without any ignorance of
the law or procedure in the subsequent orders he issued.

Disposition:
Judge Winlove M. Dumayas was found guilty of gross ignorance of the law or procedure and ordered to
pay a fine. The complaint filed by Francis R. Yuseco, Jr. was dismissed for lack of merit.

Case #13

Title of the Case:

Philippine National Construction Corporation vs. Hon. Jesus B. Mupas, Presiding Judge, Branch 112,
Regional Trial Court, Pasay City

Citation:
A.M. No. RTJ-20-2593 Formerly: OCA IPI No. 20-5067-RTJ, November 10, 2020

Ponente:
Per Curiam

Doctrine:
Judges are expected to be circumspect in the performance of their tasks, for it is their duty to administer
justice in a way that inspires confidence in the integrity of the justice system. They should exhibit more
than just a cursory acquaintance with statutes and procedural rules, and should be diligent in keeping
abreast with developments in law and jurisprudence. Gross ignorance of the law is the disregard of basic
rules and settled jurisprudence. To constitute gross ignorance of the law, the acts complained of must
not only be found erroneous but, most importantly, it must also be established that he was moved by
bad faith, dishonesty, hatred, or some other like motive.

Facts:
The Philippine National Construction Corporation (PNCC), a government-owned and/or controlled
corporation, filed an administrative complaint against Hon. Jesus B. Mupas for issuing injunctive reliefs
(Temporary Restraining Order and Writ of Preliminary Injunction) in favor of lessees whose contracts had
expired and refused to vacate PNCC's property, thereby contravening established legal procedures and
principles. PNCC argued that Judge Mupas enjoined an act that had already been accomplished and
directly contravened the Rules on Summary Procedure by taking cognizance of a case not permissible
under the said rules. Judge Mupas defended his actions by invoking the principle of liberality and the
opportunity to afford parties the chance to be heard.
Issue:
Whether or not Judge Jesus B. Mupas exhibited gross ignorance of the law in issuing injunctive reliefs in
Civil Case Nos. R-PSY-18-3000-CV and R-PSY-19-03785-CV, warranting administrative sanctions.

Ruling:
The Supreme Court found Judge Jesus B. Mupas guilty of three counts of gross ignorance of the law for:
(1) issuing a Temporary Restraining Order in Civil Case No. R-PSY-18-3000-CV without legal basis, (2)
taking cognizance of the petition for certiorari in Civil Case No. R-PSY-19-03785-CV in violation of Section
19 (g) of the Rules of Summary Procedure, and (3) issuing a Temporary Restraining Order also in Civil
Case No. R-PSY-19-03785-CV. The Court imposed fines amounting to a total of P125,000.00 for the first
two counts and dismissed Judge Mupas from the service for the third count, with forfeiture of all his
retirement benefits, except his accrued leave credits, and with perpetual disqualification for re-
employment in any branch, agency, or instrumentality of the government.

Disposition:
Judge Jesus B. Mupas was fined a total of P125,000.00 and dismissed from service, with forfeiture of his
retirement benefits except for accrued leave credits, and perpetually disqualified from re-employment in
any government agency or instrumentality, including any government-owned and controlled corporation
or government financial institution.

Case #14

Title: Office of the Court Administrator vs. Former Presiding Judge Owen B. Amor, Regional Trial Court,
Branch 41, Daet, Camarines Norte

Citation: A.M. No. RTJ-00-1535, November 10, 2020

Ponente: Per Curiam

Doctrine:
The Supreme Court retains jurisdiction over administrative cases against judges even after their
resignation, retirement, or separation from office. An administrative proceeding is independent from a
criminal proceeding, and a judge's administrative liability may arise from acts constituting gross
misconduct, which undermines public confidence in the judiciary.

Facts:
P/Supt. Danilo C. Manzano filed an administrative complaint against Judge Owen B. Amor for soliciting
PHP 400,000 in exchange for dismissing criminal cases pending in his court, constituting a violation of
Section 3(e) of R.A. 3019 (Anti-Graft and Corrupt Practices Act) and Section 7(d) of R.A. 6713 (Code of
Conduct and Ethical Standards for Public Officials and Employees).

The Sandiganbayan acquitted Judge Amor in two of the criminal cases but convicted him in one, for
which he was granted probation and later discharged, extinguishing his criminal liability.
Despite his resignation, the administrative case proceeded, focusing on Judge Amor's act of solicitation,
separate from the outcome of the criminal cases.

Issue:
Whether or not former Judge Owen B. Amor is administratively liable for soliciting money from a party-
litigant, constituting gross misconduct, despite his resignation from office and the resolution of related
criminal cases.

Ruling:
The Supreme Court found Judge Owen B. Amor administratively liable for gross misconduct due to his
act of soliciting money from a party-litigant.

The Court emphasized that cessation from office does not render moot the administrative liability
incurred during the tenure of the respondent.

Given the gravity of Judge Amor's actions and their detrimental impact on the integrity of the judiciary,
the Court imposed penalties equivalent to those for dismissal from service, including forfeiture of
retirement benefits (except accrued leave credits) and disqualification from re-employment in any
government position.
The administrative case's resolution independently of the criminal cases underscores the judiciary's
commitment to maintaining its integrity and the public's trust.

Disposition:
Former Judge Owen B. Amor is declared guilty of gross misconduct, with his retirement benefits forfeited
except for accrued leave credits, and is barred from re-employment in any branch or instrumentality of
the government, including government-owned or controlled corporations. The resolution is declared
immediately executory.

Case #15

Title: Office of the Court Administrator vs. Hon. Evelyn A. Atienza-Turla, Presiding Judge, Branch 40,
Regional Trial Court, Palayan City, Nueva Ecija

Citation: A.M. No. RTJ-21-005 (Formerly A.M. 20-11-161-RTC), December 09, 2020

Ponente: Justice Gaerlan

Doctrine:
The Constitution mandates the speedy disposition of cases to uphold the right to a speedy trial and a
speedy disposition of cases. Judges are required to decide cases within the period set by law, and failure
to do so constitutes gross inefficiency warranting administrative sanctions.

Facts:
A judicial audit in the Regional Trial Court (RTC) of Palayan City, Nueva Ecija, revealed a total caseload of
833 cases under Judge Evelyn A. Atienza-Turla, who had compulsory retired. The audit found instances of
undue delay in rendering decisions, unresolved motions and incidents, mismanagement, and
unorganized case records.

An exit conference scheduled with court employees was unattended except for one utility personnel,
with most court employees participating in a marathon without proper authorization.

The Office of the Court Administrator (OCA) recommended re-docketing the matter as a regular
administrative matter against retired Judge Atienza-Turla and imposing a fine equivalent to three
months' salary at the time of her retirement, to be deducted from her retirement/gratuity benefits.

Issue:
Whether or not Judge Evelyn A. Atienza-Turla is administratively liable for undue delay in rendering
decisions or orders, and what appropriate penalty should be imposed considering her retirement.

Ruling:
The Supreme Court found Judge Evelyn A. Atienza-Turla guilty of the less serious charge of undue delay
in rendering a decision or order. The Court emphasized the importance of the judiciary's commitment to
timely justice and found Judge Atienza-Turla's failure to decide cases and resolve pending motions within
the reglementary period as gross inefficiency.
Considering Judge Atienza-Turla's retirement, the Court imposed a penalty of a fine equivalent to three
months' salary at the time of her retirement, to be deducted from her retirement/gratuity benefits.

The Court also directed specific court employees to explain their unauthorized absence during the
scheduled exit conference and ordered the Officer-in-Charge to undertake measures to organize the
court's case records and expedite the disposition of pending cases.

Disposition:
The Supreme Court imposed a fine on retired Judge Evelyn A. Atienza-Turla for undue delay in rendering
decisions or orders and directed actions to address the administrative issues identified during the judicial
audit of the RTC of Palayan City, Nueva Ecija.