G.R. No. 172588 - Guzman vs. Guzman

Multiple administrative cases were filed against Judge Jose T. Bartolome of RTC Branch 5, Dinalupihan, Bataan, arising mainly from allegations of gross misconduct.
The charges originated with a newspaper column (“On Target”) by Ramon Tulfo in the Philippine Daily Inquirer, alleging that the judge extorted money from litigants by requiring bail bond payments to be made payable to his deputy sheriff, which eventually benefited him personally.

Following Tulfo’s publication (November 15, 1989), the Court, upon receipt of information, issued a resolution directing the Court Administrator to investigate the matter.
On January 25, 1990, then Court Administrator Meynardo Tiro filed a complaint documenting:

The issuance of orders by Judge Bartolome allowing the deputy sheriff, Antonio Leano, to receive bail payments in his (the sheriff’s) name instead of the Clerk of Court.
Specific reference to criminal cases (Nos. DH-044-88, DH-035-88, DH-047-87) pending before the judge’s court, with orders that purportedly facilitated the misappropriation of funds.
Testimonies and a letter denouncing the judge for allegedly accepting bribes from parties litigating before his court.

The National Bureau of Investigation (NBI) was involved to further probe the allegations, and a report was later forwarded confirming “truth to the allegation about the corrupt and nefarious practices” of the judge.

Initially, on March 12, 1990, in his answer, the judge admitted to issuing certain orders related to the acceptance of bail payments.

He explained that such orders were necessary due to the insolvent condition of the bondsman and to secure future payment, and that one order was directed for funds to be turned over to the Clerk of Court.
He denied having received any personal benefit from the payments, particularly the sum of P14,000.00.

Later, on September 27, 1990, he filed an additional answer denying the allegations in specific cases, defending his decisions and challenging the credibility of information sources (such as Mr. Tulfo).

Publishers of local Bataan newspapers accusing the judge of violating Presidential Decree No. 1079 by not following the mandated “raffle system” in the distribution of judicial notices.
Bataan Governor Leonardo B. Roman requesting the judge’s transfer due to “numerous complaints on nefarious activities.”

The case was referred to Justice Oscar Herrera of the Court of Appeals for a detailed investigation and report.
Justice Herrera’s report found Judge Bartolome guilty of gross misconduct based on the compiled evidence and witness testimonies.

Orders authorizing the deputy sheriff to accept bail payments were improper, as Leano was not a bonded officer and the checks were issued in his name, effectively converting official funds to a personal capacity.
The judge was implicated in engaging in a cover-up by falsifying evidence:

He instructed his clerk, Marissa Bondoc, to prepare an antedated receipt to indicate that funds had been turned over to the court.
He arranged for deputy sheriff Leano to sign a prepared Sinumpaang Salaysay (sworn statement) that purportedly absolved his involvement in the misappropriation.

The judge’s actions were seen as an attempt to shift blame onto his subordinate while evading personal accountability.

The judge’s use of an alternative “rotation system” for the distribution of judicial notices was assessed against the mandatory raffle system prescribed by Presidential Decree No. 1079.
This deviation was viewed as a means to circumvent the law, thereby inviting favoritism and undermining the integrity of judicial procedures.

Whether Judge Bartolome’s orders authorizing the deputy sheriff to accept bail bonds payments were in violation of legal and procedural requirements.

Was the acceptance of bail money by a deputy sheriff, in his personal or unofficial capacity, authorized under existing rules?
Did such orders facilitate a conduit for misappropriation of public funds?

Whether the judge’s adoption of a “rotation system” in the publication of judicial notices violated Presidential Decree No. 1079, which mandates a raffle system.

Can the judge’s justification of equitable distribution among periodicals be accepted given the explicit statutory requirement?
Does the deviation from the prescribed method contribute to an appearance or reality of favoritism and corruption?

Whether the subsequent cover-up measures, including the fabrication of evidence through falsified receipts and affidavits, compounded his misconduct.

Do these acts of falsification indicate an attempt to mislead the investigating authorities?
How do these actions affect the credibility of the judge and the validity of his explanations?

Whether the cumulative misconduct and violation of judicial protocols warrant the imposition of the disciplinary sanction of dismissal from the service, along with the forfeiture of retirement benefits and barring from future public office.