Title
Monte vs. Puno
Case
A.M. No. 1220-CFI
Decision Date
Mar 17, 1981
Judge Puno faced allegations of bias and abuse in Clara Difio's intestate case; complainants withdrew claims citing insufficient evidence.

Case Digest (G.R. No. 185664)
Expanded Legal Reasoning Model

Facts:

Background of the Case
The complaint was filed by Crisostomo D. Monte, Felina D. Monte, Honorio D. Monte, and Mateo D. Monte, Jr. against Judge Benigno M. Puno of the Court of First Instance of Bulacan, Baliuag Branch IV (later of the Court of First Instance of Quezon Province, Lucena City Branch II). The complainants alleged grave abuse of authority by Judge Puno in handling the intestate case of the late Clara Difio, Special Proceedings No. 447-B.

Key Allegations

  • Order Declaring Solomon Difio as Heir: On July 10, 1975, Judge Puno issued an order declaring Solomon Difio, born to Magdalena de la Cruz at the age of 68, as the brother of Clara Difio and entitled to half of her estate. The complainants contested this, arguing that the filiation was biologically implausible.
  • Authorization to Sell Estate Properties: On October 14, 1975, Judge Puno authorized Solomon Difio to sell or mortgage estate properties. The complainants claimed this was hastily approved, and the lawyer for the buyers was a close friend of the judge.
  • Informal and Irregular Proceedings: The complainants alleged that Judge Puno conducted informal hearings, interrogated Solomon Difio without cross-examination, and issued orders adverse to their interests. They also claimed that transcripts of hearings were tampered with.
  • Bias and Favoritism: The complainants accused Judge Puno of favoring Solomon Difio, citing incidents such as the judge’s remarks during hearings and the involvement of the clerk of court in notarizing deeds of sale.
  • Allegations of Corruption: The complainants alleged that Judge Puno’s bodyguard and mechanic, Eugenio Baluyot, solicited bribes on his behalf.
  • Complaints to Higher Authorities: The complainants escalated their grievances to the President of the Philippines, the Chief Justice, and Radio Veritas, denouncing Judge Puno’s actions as unjust and abusive.

Respondent Judge’s Defense
Judge Puno denied the allegations, stating he had no personal interest in the case and that the Court of Appeals had denied the complainants’ petition for certiorari challenging his July 10, 1975 order. He also noted that the case was later assigned to Judge Mariano Castaneda, Jr.

Issues:

  • Whether Judge Benigno M. Puno committed grave abuse of authority in issuing orders in the intestate case of Clara Difio.
  • Whether Judge Puno exhibited bias and favoritism in favor of Solomon Difio.
  • Whether the allegations of corruption and irregular proceedings against Judge Puno were substantiated.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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