G.R. No. 212815 - People vs. Donio y Untalan

The administrative case arose from counter-charges filed by Presiding Judge Marigel S. Dagani-Hugo (Judge Hugo) against Judge Dennis B. Castilla (Judge Castilla) of the Municipal Trial Court in Cities, Butuan City, Agusan del Norte.
Originally, Judge Castilla had filed charges against Judge Hugo in a Complaint dated September 7, 2017, alleging various acts of misconduct during her tenure as a provincial prosecutor.
The complaint detailed several allegations, including the dismissal of criminal cases (theft and estafa counts) allegedly due to favoritism linked to Judge Hugo’s fraternity membership, an improperly handled rape case, a conspiracy with a process server to file a baseless perjury charge, misconduct regarding parking space reassignment, and collusion with Judge Castilla’s former wife in filing a VAWC complaint against him.

It was alleged that while still a provincial prosecutor, Judge Hugo caused the dismissal of multiple criminal cases against certain accused individuals by bias.
A second allegation pertained to the dismissal of a rape case, raising concerns over the integrity of the decision.
The complaint further claimed that Judge Hugo, in association with her process server, fabricated charges of perjury against Mary Grace E. Wang.
An additional allegation involved an incident on September 5, 2017, where Judge Hugo allegedly reassigned Judge Castilla’s long-used parking space without due process, causing humiliation and inconvenience.
Lastly, it was contended that Judge Hugo colluded with Climarie Castilla (Judge Castilla’s former wife) in initiating a case against him under Republic Act No. 9262 (VAWC).

In her Comment dated November 23, 2017, Judge Hugo refuted all allegations, attributing the complaint to personal animosity on the part of Judge Castilla.
She explained that the dismissal of the theft and estafa cases was based on the recommendation of prosecutorial personnel and later sustained by the Department of Justice (DOJ).
Judge Hugo denied any involvement in the alleged dismissal of a rape case, labeling it as mere hearsay.
She also repudiated any role in the filing of the perjury case against Wang and clarified the rationale behind the parking reassignment, based on security concerns following a high-profile murder.
On February 1, 2018, Judge Hugo escalated her defense into a counter-complaint against Judge Castilla, alleging his own misconduct which included:

Disrespect for the hierarchy of courts.
The use of insulting language towards his colleagues.
Failure to adhere to office memoranda.
An improper personal involvement with a lawyer from the Public Attorney’s Office (PAO).

To support her counter-charges, Judge Hugo submitted various documents, including:

A copy of an Omnibus Order showing Judge Castilla’s disregard of a directive from another branch of the RTC.
An Order of Dismissal containing allegedly insulting remarks.
An affidavit attesting to non-compliance with office memoranda on flag ceremonies.
A transcript of text messages purportedly evidencing an illicit relationship with a PAO lawyer.

Judge Castilla, in his Reply dated April 16, 2018, reiterated his initial allegations against Judge Hugo and submitted documentary evidence in support thereof.
The Office of the Court Administrator (OCA) recommended that the conflicting claims be subjected to a formal investigation.
A Resolution dated October 10, 2018, referred the matter to the Executive Justice of the Court of Appeals, Cagayan de Oro City, with a directive for investigation and report within 90 days.
Investigating Justice Oscar V. Badelles eventually found probable cause against Judge Castilla for alleged violations of Canons 2 and 4 of the Code of Judicial Conduct, recommending administrative elevation and imposing a fine of ₱40,000.00 with a stern warning.
On January 8, 2020, the court dismissed the complaint against Judge Hugo for lack of merit and treated the counter-charges against Judge Castilla as a separate matter, which led to Judge Castilla’s Most Urgent Manifestation/Appeal for Dismissal filed on June 1, 2020.

Whether Judge Castilla is administratively liable for the following alleged acts:

Disrespecting the hierarchy of courts by allegedly interfering with or overstepping his jurisdiction.
Using insulting language towards his colleagues, as exemplified by certain orders that contained inappropriate remarks.
Failing to comply with office memoranda, particularly regarding the observance of flag raising and flag lowering ceremonies.
Engaging in an improper relationship with a PAO lawyer, as inferred from the transcript of text messages submitted by Judge Hugo.

Whether the evidence presented by Judge Hugo satisfies the required threshold of competence and direct knowledge necessary to support the administrative charges against Judge Castilla.