Title
Calleja vs. Santelices
Case
A.M. No. RTJ-99-1443
Decision Date
Mar 14, 2000
Judge Rafael P. Santelices fined P5,000 for gross inefficiency, disrespect to the Supreme Court, and procedural lapses in handling Civil Case No. 9441, with a warning against future misconduct.
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Case Digest (A.M. No. RTJ-99-1443)

Facts:

  1. Complaint Against Judge Rafael P. Santelices:

    • Complainant Evan B. Calleja filed a sworn letter-complaint on December 3, 1997, charging Judge Rafael P. Santelices of the Regional Trial Court (RTC) of Legaspi City, Branch 2, with manifest partiality and gross ignorance of the law in connection with Civil Case No. 9441 ("Mayon International Hotel, Inc. vs. Albay Electric Cooperative, Inc., Edgardo San Pablo, and Evan B. Calleja").
  2. Allegations in the Complaint:

    • Electricity Pilferage: Complainant alleged that during the hearing on October 17, 1997, the plaintiff (Mayon International Hotel) admitted to electricity pilferage, but the respondent judge ignored this and proceeded with the case.
    • Injunction Bond: The complainant claimed that the respondent judge fixed the injunction bond at P200,000.00, ignoring the differential billing computation of P1,454,381.50 submitted by the defendants.
    • Failure to Report Injunction: The respondent judge issued a writ of preliminary mandatory injunction but failed to submit a report to the Supreme Court within 10 days, as required by Section 9 of R.A. No. 7832.
    • Disrespect to the Supreme Court: During the hearing on November 12, 1997, the respondent judge allegedly cut short the defense counsel’s invocation of a Supreme Court circular, saying, “Never mind, let the Supreme Court have that circular.”
    • Reimbursement Order: The respondent judge ordered the defendants to reimburse the transportation expenses and appearance fee of the plaintiff’s counsel after a postponement request.
  3. Second Administrative Complaint:

    • On February 25, 1998, the complainant filed another administrative complaint, alleging:
      • Partiality towards the plaintiff due to the influence of Atty. Manuel M. Lazaro, who was instrumental in the respondent judge’s appointment to the judiciary.
      • Failure to send a Notice of Raffle as required by Supreme Court Circular No. 20-95.
      • Premature setting of the pre-trial despite the absence of the last pleading.
      • Distortion of records in Civil Case No. 9441 by issuing conflicting orders regarding the motion to inhibit.
  4. Respondent Judge’s Defense:

    • The respondent judge denied the allegations, stating that the plaintiff was not caught in flagrante delicto and that the bond amount was subject to adjustment.
    • He admitted to failing to report the injunction but claimed it was not deliberate.
    • He apologized for his remark about the Supreme Court circular but maintained that he did not intend to disrespect the Court.
    • He justified the reimbursement order, stating that the plaintiff’s counsel was not notified of the postponement.
  5. OCA’s Findings and Recommendations:

    • The Office of the Court Administrator (OCA) found that some issues were sub judice and recommended:
      • A fine of P10,000.00 for gross inefficiency and disrespect to the Supreme Court.
      • A reprimand for violating Canon 2, Rule 2.01 of the Code of Judicial Ethics.
      • Dismissal of the remaining charges.

Issue:

  1. Whether the respondent judge committed manifest partiality and gross ignorance of the law in handling Civil Case No. 9441.
  2. Whether the respondent judge’s failure to report the issuance of a writ of preliminary mandatory injunction to the Supreme Court constitutes gross inefficiency.
  3. Whether the respondent judge’s remark, “Never mind, let the Supreme Court have that circular,” constitutes disrespect to the Supreme Court.
  4. Whether the respondent judge’s order for the defendants to reimburse the plaintiff’s counsel’s expenses was proper.
  5. Whether the respondent judge violated procedural rules in setting the pre-trial and issuing conflicting orders.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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