IPI No. 17-267-CA-J - Re: Mariflor Punzalan-Castillo

Fernando Castillo, a lay litigant and brother-in-law of the respondent, filed a Verified Complaint against Associate Justice Mariflor Punzalan-Castillo of the Court of Appeals.
The complaint arose from a family dispute involving the transfer of land titles from the father to Fernando Castillo’s name, amid contested transactions among siblings.
The complaint is heavily interlaced with personal and familial animosities, as evidenced by the public nature of the allegations and the involvement of multiple family members.

It is alleged that during a public interview before the Judicial and Bar Council (JBC) in January 2016, Justice Punzalan-Castillo accused Fernando Castillo of document falsification without proof.
The complainant avers that such statements constituted grave slander under Section 20(f), Rule 138 of the Rules of Court, as he did not get any chance to defend his character afterward.

The complaint accuses the justice of misrepresenting her involvement in a land dispute between the complainant and his siblings during the JBC interview.
Specifically, it is claimed that she falsely stated she had no personal involvement because the case was attributable to her husband’s family, while she was in fact one of the plaintiffs in a pending RTC-Malolos case.

The complainant alleges that pleadings submitted before the RTC-Malolos originated from the Court of Appeals, allegedly drafted using CA personnel and facilities.
An annotation on one such pleading—“dina.justice.motion for execution”—and the presence of an employee named “Dina” led to the conclusion that Justice Punzalan-Castillo was exploiting her office for personal and private interests.

It is claimed that the justice did not recuse herself in a petition for certiorari filed by Bangko Sentral ng Pilipinas, despite a conflict of interest arising from her familial and business ties.
The allegation rests on the fact that her husband and a group associated with the opposing party were linked through a partnership in the Rural Bank of Calumpit.

The complainant narrates that in a pending RTC-Malolos case, the justice—together with her husband—allegedly maneuvered to secure false testimony by having Atty. Rolando Dazzle E. Ty posed as counsel for a co-defendant, Atanacio Paulino, despite his evident reluctance.
A subsequent denial by Paulino of Atty. Ty’s representation further bolstered the complainant’s claim of a conspiracy.

Based on an examination by an NBI handwriting expert, the complaint contends that entries in pleadings (including the title number, date, and place of issue) were written by a single person, thereby suggesting falsification.
Furthermore, an incident involving a real estate mortgage notarized by the justice in 1979 is cited, wherein the justice’s name was inexplicably erased and the complainant’s mother’s signature was alleged to have been forged.

Justice Punzalan-Castillo dismissed the allegations as malicious, baseless, and stemming from the complainant’s personal grievances amid an ongoing family dispute over land titles.
She clarified that her public statements during the JBC interview were made in the context of defending her brother-in-law’s position in a broader dispute involving document falsification committed by the complainant.

Regarding the accusation of lying under oath, she maintained that her statements concerning the lack of willingness for compromise were based on her direct involvement in family mediation and procedural meetings.
On the use of CA resources, she explained that an available template was copied to avoid reformatting documents and that the annotation was simply a filing aid for future reference.
On the issue of recusal, she argued that the names associated with the case did not signal any conflict of interest warranting her inhibition, and that neither she nor her husband were involved in the alleged partnership intended to influence proceedings.

Justice Punzalan-Castillo refuted the claim that she manipulated the appearance of legal representation for Atanacio Paulino, asserting that proper procedures were followed in the RTC-Malolos case.
She also questioned the evidentiary basis of the handwriting analysis, noting that only photocopies—not originals—were examined, thereby rendering the conclusions unreliable.

Whether the allegations against Justice Punzalan-Castillo provide sufficient grounds for her disbarment or removal from the appellate court.
Whether the acts attributed to her—ranging from slander and perjury to forgery and misuse of court resources—constitute violations of the Rules of Court and the Code of Judicial Conduct.
Whether the evidence presented by the complainant is substantial and credible enough to meet the burden of proof required for condemning a judiciary member.
Whether judicial and administrative complaints based largely on speculative or unverified assertions can justify punitive measures against a sitting justice.