A.M. No. MTJ-02-1433 - Leonidas vs. Supnet

Case Summary (A.M. No. MTJ-02-1433)

Allegations Against Respondent Judge

Petitioner Tomas R. Leonidas alleges that respondent Judge Francisco G. Supnet committed gross ignorance of the law, grave abuse of authority, and misconduct by holding him in contempt of court. This contention arose from the judge's citation of Leonidas for indirect contempt due to his involvement with an unresolved case in which Union Bank sought to collect an unpaid loan from the spouses Eddie and Eliza Tamondong.

Factual Background of the Case

In April 1998, Union Bank, represented by Leonidas, initiated a complaint for replevin against the Tamondong spouses. After various procedural setbacks, including a dismissal for lack of interest to prosecute and a motion for reconsideration, the court reinstated the case but ultimately dismissed it again in June 1999. Subsequently, in March 2000, Union Bank filed a new complaint against the same defendants in the Metropolitan Trial Court of Pasay City, leading to the issuance of a writ of replevin.

Orders Issued by the Pasay MTC

The MTC, responding to motions filed by the Tamondong spouses, dismissed the case, revoked the writ of replevin, and ordered the return of the vehicle. Citing violations of the forum shopping rule and false certification, the MTC imposed fines on Union Bank, its officers, and Leonidas, marking the first instance of contempt.

Motion for Reconsideration and Further Proceedings

After the MTC’s order, Union Bank sought reconsideration but later filed a notice of dismissal. The MTC denied the motion for reconsideration and subsequently issued another order compelling Union Bank to show cause for its non-compliance with the previous order, leading to a second contempt citation against Leonidas.

Grounds for Administrative Complaint

Leonidas argues that the contempt order was erroneous as it was addressed solely to Union Bank and not to him. He contends that he should not be culpable for a false certification concerning forum shopping as he did not sign it. Additionally, he alleges that due process was violated because the contempt charges initiated by the Tamondong spouses were not done through a verified petition as required by the 1997 Rules.

Respondent’s Defense

In his defense, Judge Supnet maintains that he adhered to procedural requirements when issuing the contempt orders and cites judicial discretion afforded to him in managing cases of contempt. He argues that holding him accountable for every erroneous decision would obstruct judicial function.

Findings of the Office of the Court Administrator (OCA)

The OCA determined that while the first contempt was justifiable, the second contempt was flawed due to improper initiation without a verified petition, which contravenes established procedural rules. Hence, it recommended a fine for the judge but found no grounds for administrative liability regarding the first contempt order.

Court’s Ruling and Final Recommendations

The Cour