G.R. No. 225565 - Camp John Hay Development Corp. vs. Office of the Ombudsman

Complainant Nonato Barroso, a retired former stenographer who once rendered services in the respondent judge’s court, filed an Administrative Complaint on March 13, 1973.
The complaint was directed against Judge Andres P. Arche, CFI, Branch II, Borongan, Eastern Samar, reflecting Barroso’s dissatisfaction with an adverse decision in his personal case.

The personal case involved a claim against the Government Service Insurance System (GSIS) where Barroso sought the recovery of retirement benefits.
Barroso’s claim was based on his own computation, demanding a total sum of ₱38,874.00, compared to the ₱22,590.00 actually paid by the GSIS under the standard basis.
The adverse decision rendered by Judge Arche on January 4, 1972, upheld the standard computation used by the GSIS rather than Barroso’s interpretation.

The administrative complaint was filed as an aftermath of Judge Arche’s adverse ruling and charged him with dishonesty, oppression, incompetence, and inefficiency.
The issues raised in the administrative complaint were identical to those Barroso had earlier assigned as errors on appeal from the same adverse decision.
Barroso had already filed an appeal on January 31, 1973, with the Court of Appeals, and the administrative complaint sought to reopen the issues during the pendency of the appeal.

The case was referred through the Secretary of Justice to the Court on May 24, 1973, after receipt of the respondent’s Comments.
The investigation was undertaken by Justice Sixto Domondon of the Court of Appeals, who was tasked to probe, report, and recommend findings regarding the administrative complaint.
Justice Domondon submitted his report on July 24, 1975, noting that he had intentionally delayed the report because the facts and issues were concurrently raised on appeal (pending assignment and decision).

The investigating Justice observed that the administrative complaint was a reiteration of errors already raised in the pending appeal.
No significant evidence was adduced during the investigation to show that Judge Arche had exhibited any bias or malice in reaching his decision.
The deduction of retirement benefits by the GSIS was approved by Judge Arche after what appeared to be a thorough appreciation of evidence.
The charge of neglect of duty (asserting that the case was decided after a lapse of 90 days) was found to have no factual basis, as supported by the clerk of court’s certification outlining the proper timeline from filing to decision.

Whether the administrative complaint was properly filed while there was a pending appeal challenging the same errors in the judge’s adverse decision.
Whether a litigant should pursue an administrative complaint concurrently with his judicial appeal.

Whether the allegations of dishonesty, oppression, incompetence, and inefficiency against Judge Arche are substantiated by sufficient evidence.
Whether the judge’s ruling to uphold the GSIS’s standard computation of retirement benefits, as opposed to the complainant’s computation, constitutes a reversible error or shows any sign of wrongful conduct.

Whether the delay in the processing of Barroso’s personal case (filed on August 28, 1970 and decided on January 4, 1972) justifies the charge of neglect of duty against the judge.
The appropriateness of filing a separate administrative complaint on issues that are already under judicial scrutiny in an appeal.