Title
Sy vs. Fineza
Case
A.M. No. RTJ-03-1808
Decision Date
Oct 15, 2003
Judge Fineza accused of bribery, harassment, and abuse of authority; found guilty of serious misconduct, suspended for six months.

Case Digest (A.M. No. RTJ-03-1808)
Expanded Legal Reasoning Model

Facts:

  • Filing of Complaints and Nature of Allegations
    • A verified complaint dated May 22, 2001, was filed by Radelia C. Sy with the Office of the Court Administrator.
    • The complaint charged Judge Antonio J. Fineza, Presiding Judge of RTC Caloocan City (Branch 131), with bribery, grave misconduct, conduct unbecoming of a judge, and conduct prejudicial to the best interest of the service.
    • Complainant Sy, also the accused in a pending estafa case before the same judge, alleged that the judge pressured her by offering to dismiss her estafa case in exchange for money, or, failing that, threatened to convict her regardless of her innocence.
  • Alleged Bribery and the Chronology of Payments
    • On March 22, 2000, inside Steak Town Restaurant in West Avenue, Quezon City, Sy delivered P30,000 to Judge Fineza in the presence of her lawyer (Atty. Petronilo dela Cruz) and legal researcher Robert Cheng.
    • During the first week of May 2000, she made her second payment of P20,000 inside the judge’s chambers.
    • Later in the same week, at Steak Town Restaurant, she made a third payment of P30,000, witnessed by Atty. dela Cruz, Mr. Cheng, and a certain Cristy Yambao.
    • Also at Steak Town Restaurant, on or about May 19, 2000, a fourth payment of P25,000 was delivered in the presence of Atty. dela Cruz, Mr. Cheng, and Erwin Cato.
    • In June 2000, through her lawyer Atty. dela Cruz, she advanced P50,000 which she later reimbursed.
    • On July 20, 2000, at Barrio Fiesta Restaurant in Edsa, Sy handed over P100,000 to Judge Fineza in the presence of Mr. Cheng.
  • Events of Harassment and Procedural Irregularities
    • When Sy failed to complete the remaining balance, Judge Fineza allegedly began harassing her.
    • On December 8, 2000, during a hearing, he cited her for direct contempt after inquiring about the renewal of her bail bond.
    • Sy, having presented a receipt from Pacific Union Insurance Company issued by Evelyn delos Santos, was barred from leaving the courtroom.
    • Despite fetching Ms. delos Santos to verify the bail bond, Sy was informed that an arrest order had been issued.
    • The initial Order of Arrest did not specify the penalty details; it was later amended to impose a 5-day imprisonment and a fine of P5,000.
  • Increase of Bail and Subsequent Misconduct
    • On March 29, 2001, as Sy was about to complete serving her sentence for contempt, Judge Fineza increased her bail from P200,000 to P1,000,000.
    • A second verified complaint dated July 3, 2001 was jointly filed by Sy and Erwin Cato, charging the judge with abuse of authority, grave misconduct, and oppression.
    • This complaint alleged that during a May 21, 2001 hearing, Judge Fineza shouted demeaning and disparaging remarks in open court directed primarily at her lawyers.
    • It also included an incident where, on June 26, 2001, while in the court hallway, the judge allegedly pointed his finger at Cato, uttering defamatory words.
  • Proceedings Before the Investigating Justice
    • On March 13, 2002, Deputy Court Administrator Christopher O. Lock filed his report recommending referral to an Associate Justice of the Court of Appeals for investigation.
    • The case was referred to Associate Justice Eugenio S. Labitoria on June 5, 2002.
    • Both parties agreed to forego the reception of live evidence and instead submitted position papers with documentary evidence and affidavits by November 26, 2002, with Judge Fineza filing a reply on January 14, 2003.
    • A rejoinder was subsequently filed by Sy and Cato on February 12, 2003, which was answered by Judge Fineza on February 27, 2003.
  • Findings of the Investigating Justice and Evidence Presented
    • The investigating justice found no merit in the bribery charge, noting the insufficient, uncorroborated nature of the evidence (primarily affidavits from Sy’s friends).
    • However, the judge’s actions—including harassing Sy through a contempt citation, wrongful imprisonment orders, and the unilateral increase in bail—were considered abuses of authority.
    • Evidence also pointed to additional instances of misconduct, such as referring disparagingly to a witness as “BAKLA” in a pleading and demeaning conduct towards complainant Cato and counsel Atty. Jubay.
  • Determination and Penalty Imposed
    • The initial recommendation was to reprimand Judge Fineza and fine him one month’s salary for simple misconduct.
    • Further consideration and analysis revealed that the acts exhibited malice and bad faith, rising to the level of serious misconduct.
    • The Court decided that Judge Fineza’s acts were not mere errors of judgment but egregious abuses of his judicial office.
    • Ultimately, Judge Fineza was suspended from office without salary and other benefits for six (6) months with a stern warning that any subsequent transgression would result in his dismissal.

Issues:

  • Whether the series of monetary transactions alleged by complainant Sy constituted bribery or some form of improper exchange influencing judicial decisions.
  • Whether Judge Fineza abused his authority by:
    • Imposing a direct contempt citation and ordering arrest for trivial reasons.
    • Unilaterally increasing bail from P200,000 to P1,000,000 without affording the complainant adequate procedural safeguards.
  • Whether the alleged public and private derogatory statements (including insults in open court and in the courthouse hallway) amounted to behavior unbecoming of a judge.
  • Whether the evidence presented, including conflicting affidavits, was sufficient to establish serious misconduct on the part of Judge Fineza.
  • Whether the disciplinary sanction imposed was appropriate in light of the gravity of the misconduct and the need to maintain judicial integrity.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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