The Supreme Court's Ruling in A.M. No. RTJ-22-022 [Formerly OCA I.P.I. No. 19-4966-RTJ]

October 5, 2022

OCA CIRCULAR NO. 264-2022

 

On 23 August 2022, the Court En Banc, speaking through Associate Justice Maria Filomena D. Singh, promulgated its Decision in A.M. No. RTJ-22-022 [Formerly OCA I.P.I. No. 19-4966-RTJ], entitled Governor Edgardo A. Tallado, et al. vs. Hon. Winston S. Racoma, Presiding Judge, Branch 39, Regional Trial Court, Daet, Camarines Norte. To highlight, the Court considered the filing by the complainants, who are influential elective officials, of the instant administrative case as unscrupulous and a form of harassment on respondent judge, wherein "not even the [Code of Judicial Conduct] can protect [the judge] from the hardships occasioned by discordant and moreso openly adversarial relations with the said officials."

Thus, in acknowledging that judges regularly face and live with this unhealthy environment, day in and day out, and in order "to safeguard against abuse of administrative disciplinary mechanism against justices, judges, and court personnel," the Court unanimously enunciated the following rules in evaluating administrative disciplinary cases:

1) If a judicial remedy is still available to the complainant, the administrative complaint shall be dismissed outright, without prejudice to re-filing should the complainant succeed in a judicial action in proving that the public respondent's assailed act or omission was indeed wrong and ill motivated.

2) If the administrative case is meant to harass, threaten or merely vex the public respondent. In determining this, the following factors may be considered:

a) the existence of other cases filed against the public respondent by the same complainant or related complainants;

b) the position and influence of the complainant, particularly in the locality where the public respondent is stationed;

c) the number of times that the public respondent has been charged administratively and the corresponding dispositions in these cases;

d) any decisions or judicial actions previously rendered by the public respondent for or against the complainant;

e) the propensity of the complainant for filing administrative cases against members and personnel of the Judiciary; and

f) any other factor indicative of improper pressure or influence.

Significantly, the Court further elucidated that "unfounded criticisms against members of the Judiciary degrade the judicial office and greatly interfere with the due performance of their functions in the Judiciary. They not only needlessly drain the resources of the Court in resolving them, they sow the seeds of distrust of the public against members of the Judiciary." As a result, the Court dismissed the subject case and directed the complainants to explain their act of filing a premature complaint against respondent judge intended to harass or vex the latter.

As a final note, the Court was emphatic in its pronouncement that it "is cognizant of the sacrifices of our judges, who risk their very lives and even those of their loved ones, in order to keep our courts open and render the services our people need. None of them is perfect. Just as none of us are. When they commit errors, it is our duty to correct them. But when their circumstances call out for consideration, we must not turn a blind eye." In addition, the Court emphasized that "a judge who discharges his or her duties despite being beset with external pressures, and who manages to fend off corrupt influences and remain true to his or her oath, save only for an occasional error in judgment, should be extended consideration and commiseration, not condemnation."

For your information and guidance.

(SGD.) RAUL B. VILLANUEVACourt Administrator