A.C. No. 203-J, 625-CFI - Secretary of Justice vs. Catolico

Background
Two administrative complaints were filed against Judge Alfredo Catolico by the Secretary of Justice and by Mrs. Fermina Olaes.
The complaints charged the judge with “serious misconduct and gross disregard of law” based on varied judicial practices and actions during his tenure in different courts.

First Complaint – Naturalization Cases
Originated in October 1965 when Judge Catolico, then acting as Judge of the Court of First Instance of Misamis Occidental, handled over fifty naturalization cases.
The judge declared, motu proprio and without any petition by the Republic of the Philippines, that the oath taking of the petitioners was null and void.
In open court, he delivered a lengthy dissertation criticizing the honesty and integrity of provincial and city fiscals involved in these cases.
He specifically targeted Chua Tuan, a Chinese multi-millionaire involved in overshipments of copra, using disparaging epithets such as “balasubas,” “ingrate,” “hambug,” “animalistic,” “a danger and a disgrace to the community,” and “a dishonor to the Filipino people.”

Second and Third Complaints – Jurisdiction and Procedural Issues
The complaints arose from the judge’s insistence that he lacked jurisdiction to try cases that had not been heard for more than thirty days after the previous hearing.
In exercising his self-appointed rule, he dismissed both civil and criminal cases on the ground that he could not continue with pending cases without a written directive from the Court.
The judge also refused to recognize the regular authority of the Court’s Clerk in transmitting official resolutions and notifications, thereby challenging established court procedures.

Fourth Complaint – Homicide Case Proceedings
Filed by Mrs. Fermina Olaes, the widow of a homicide victim, this complaint related to a trial where the arraignment was on October 3, 1973, followed by a series of hearings throughout late 1973 and early 1974.
The accusation centered on the allegation that the judge expedited the trial to secure an acquittal for the accused just before his retirement upon reaching the age of 70.
Specific incidents noted include:

During the December 26, 1973 hearing, the judge was reported to have been overly emotional—questioning the prosecution’s witness for two hours, “bullying, ridiculing, frightening, threatening, and humiliating” the witness, even resorting to banging on the table with his fist.
The judge was also criticized for making demeaning inquiries about the witness’s personal circumstances (such as questions regarding his illness) and for issuing what was perceived as a “wrapped-up decision” that presupposed acquittal.

Respondent’s Defense and Administrative Context
The judge defended his actions by asserting that his decisions and conduct were motivated by a desire to strictly enforce the rules, comply with the law, and serve the best interests of justice by ensuring a speedy resolution of cases.
In the naturalization cases, he argued that the premature taking of oaths by petitioners justified his motu proprio intervention.
He denied any personal malice or improper castigations, maintaining that any error in judgment was “of the mind rather than of the heart.”
Prior related disciplinary proceedings were noted in decisions such as People vs. Judge Alfredo Catolico (38 SCRA 389), Barrera vs. Barrera (34 SCRA 98), and Queto vs. Catolico (31 SCRA 52), where the Court had already admonished him for his disregard of proper judicial procedure and authority.

Subsequent Developments and Resolution
For the first three complaints, no further administrative proceedings took place after the judge filed his answer, due to the issues already being a matter of record.
The fourth complaint was referred to Justice Buenaventura de la Fuente of the Court of Appeals for investigation, with the report submitted on August 1, 1975, concluding that the judge’s conduct was not of a nature warranting heavy sanctions, but rather a set of eccentricities.
On April 17, 1975, the judge informed the Court that his resignation had been accepted by President Ferdinand E. Marcos, effective January 11, 1974, “without prejudice to his receiving whatever rights he may be entitled to under the retirement and other existing laws.”
Considering the acceptance of his resignation and the established policy on similar cases, the administrative cases pending against him were rendered moot and academic.

Whether the judge’s motu proprio nullification of naturalization oaths, accompanied by his disparaging remarks, constitutes serious misconduct and a gross disregard of the law.
Whether the judge’s dismissal of cases pending for more than thirty days—based on a personal interpretation of judicial jurisdiction and procedural rules—amounts to an abuse of discretionary power.
Whether his refusal to acknowledge the authority of the Court’s Clerk in transmitting resolutions and notifications demonstrates an inappropriate overreach of his judicial responsibilities.
Whether expediting the homicide trial, potentially motivated by his impending retirement, reflects judicial prejudice that undermines the fairness and due process owed to litigants, particularly the prosecution’s witness.
The significance of the prior admonishments and disciplinary actions in determining whether further administrative sanctions were necessary.
Whether the judge’s resignation, accepted by the President, terminates the need for further administrative or disciplinary proceedings against him.