Title
Supreme Court
Dagani-Hugo vs. Castilla
Case
OCA IPI No. 20-3093-MTJ
Decision Date
Oct 14, 2020
Judge Hugo accused Judge Castilla of misconduct; Castilla counter-claimed. SC dismissed both, citing lack of evidence, emphasizing judicial errors ≠ administrative liability, and requiring competent proof.

Case Summary (OCA IPI No. 20-3093-MTJ)

Allegations Against Judge Hugo

Judge Castilla filed a complaint on September 7, 2017, alleging that Judge Hugo exhibited ignorance of the law and conduct prejudicial to the best interest of service. The claims centered around Judge Hugo's actions as a provincial prosecutor related to the dismissal of criminal cases, including four theft cases and two counts of estafa against Engineer Hospicio C. Ebarle, Jr., as well as a rape case. Judge Castilla argued that Judge Hugo had a bias influenced by her affiliation with a fraternity. Additional allegations included conspiracy to file false charges against a third party and inappropriate management of parking assignments amongst judges.

Judge Hugo's Response

In her response dated November 23, 2017, Judge Hugo denied all allegations, asserting that they stemmed from Judge Castilla's personal grievances against her. She provided justifications for her past actions, citing recommendations from prosecutors and emphasizing a lack of direct involvement in any alleged misconduct. Judge Hugo further presented her own countercharges against Judge Castilla, accusing him of disrespecting court hierarchies, insulting colleagues, ignoring office memorandums, and having an inappropriate relationship with a lawyer from the Public Attorney's Office.

Investigative Proceedings

The Office of the Court Administrator (OCA) recommended a formal investigation into the conflicting allegations between the judges. The Supreme Court subsequently referred the case for investigation by Investigating Justice Oscar V. Badelles. His report found Judge Hugo not liable, while recommending administrative charges against Judge Castilla for gross misconduct due to his failure to comply with lawful court orders and for engaging improperly with a subordinate.

Court's Evaluation of Evidence

In evaluating the allegations against Judge Castilla, the Court applied the principle that the burden of proof lies with the complainant to provide substantial evidence for claims of misconduct. The Court assessed that the evidence presented by Judge Hugo lacked direct knowledge and competence. The Court concluded that instances cited involving disrespect toward hierarchy and insulting behavior were neither adequately proven nor actionable through administrative processes, as they stemmed from mere errors in judgment.

Rulings on Charges of Misconduct

The Court particularly scrutinized the allegations of illicit conduct, finding that the message exchanges presented regarding Judge Castilla's personal relationshi

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