Adm. Case No. 12 - Baptista vs. Castaneda

Complainant Catalina Z. Aliling filed a verified administrative complaint against Justice Ma. Luisa C. Quijano-Padilla of the Court of Appeals, Manila.
The complaint alleged gross ignorance of the law or procedure and gross misconduct amounting to violations of Rules 1.01 and 3.01 of the Code of Judicial Conduct.
The administrative complaint arose from a decision rendered by Justice Padilla in CA-G.R. CV No. 103042.

On 28 October 1997, Asuncion Zamora Jurado and Catalina Zamora Aliling, along with the interests of their deceased brother Fernando M. Zamora, filed a complaint before the Regional Trial Court in Santiago City, Isabela.
The dispute involved determining the true origin and ownership of a 7,086-square meter parcel of land (Lot No. 4900) covered by TCT No. T-65150, which was allegedly inherited from their father, Dominador Zamora, originally titled under TCT No. T-2291.

The plaintiffs contended that the subject land had been improperly subdivided into several titles registered in the names of various defendants, including Vicente Chai, Eduardo Sarmiento, Anastacio Pallermo, and the PariAas couple.
The plaintiffs sought the nullification of the subdivided titles, arguing that the reconstitution proceedings (particularly regarding OCT No. 3429) were irregular and that certain defendants, notably the Chai spouses, were not purchasers in good faith.

The Regional Trial Court rendered a judgment noting irregularities in the reconstitution process and questioned the good faith of some defendants.
Both parties filed motions for reconsideration before the trial court, which were denied.
On intermediate appeal, the Court of Appeals reversed and set aside portions of the trial court’s decision regarding the status of buyers in good faith, holding that the defendant spouses had indeed shown due diligence.
Justice Padilla authored the CA decision, with Associate Justices Normandie B. Pizarro and Samuel H. Gaerlan concurring.

On 27 June 2016, amidst pending judicial motions for reconsideration of the CA decision by the plaintiffs-appellees, Aliling filed the administrative complaint against Justice Padilla.
Though Aliling asserted that her complaint did not challenge the CA decision directly, the focus of her allegation pertained to the judicial ruling rendered by Justice Padilla in the context of the disputed civil case.

Whether errors committed by a judge in the exercise of adjudicative functions can be addressed through administrative proceedings rather than judicial remedies.
Whether the administrative complaint against Justice Padilla, based solely on her ruling in CA-G.R. CV No. 103042, was proper given that judicial remedies were concurrently available.

Whether Justice Padilla’s decision constituted gross ignorance of the law or procedure.
Whether the ruling involved any element of bad faith, fraud, malice, corrupt purpose, or a deliberate intention to do injustice that would justify administrative disciplinary action.

Whether it was appropriate to pursue administrative sanctions while the civil case had not reached finality and judicial remedies were still available for review.
Whether unresolved motions for reconsideration in the appellate process barred the initiation of an administrative complaint.