Title
Supreme Court
Re: Rafael Dimaano
Case
A.M. No. 17-03-03-CA, IPI No. 17-258-CA-J
Decision Date
Jul 11, 2017
Unsworn complaints alleging corruption against Justice Lantion and Atty. Cajayon dismissed by the Supreme Court due to lack of substantial evidence and technical deficiencies.

Case Summary (A.M. No. 17-03-03-CA, IPI No. 17-258-CA-J)

Petitioner and Respondent

The petitioners, Rosa Abdulharan and Rafael Dimaano, filed complaints against Justice Lantion and Atty. Cajayon. Justice Lantion is a sitting justice of the Court of Appeals, while Atty. Cajayon is a lawyer based in Zamboanga City, with a history of legal practice spanning several years.

Applicable Law

This case is governed by the 1987 Philippine Constitution and the Rules of Court that provide the framework for administering justice and disciplining members of the judiciary and legal professionals.

Allegations Made

Abdulharan's complaint, dated September 12, 2016, alleges that Atty. Cajayon solicited money from litigants for favorable rulings from Justice Lantion. Dimaano’s letter dated November 14, 2016, raises similar concerns about a syndicate allegedly operating in the Court of Appeals. Both complaints were forwarded to the Supreme Court for investigation.

Responses by the Respondents

Atty. Cajayon, in her formal answer, categorically denied any association with the complainants and refuted the accusations of solicitation or corruption. She emphasized her professionalism and integrity throughout her legal career, insisting that the claims were unfounded and intended to tarnish her reputation.

Justice Lantion also denied the charges, asserting that the allegations were generalizations lacking substantial proof. She pointed out that the unsworn letters failed to provide specific acts or evidence of any wrongdoing. Moreover, she highlighted the improbability of the allegations, given her brief tenure in Cagayan de Oro and her lack of relationship with Atty. Cajayon.

Court's Evaluation of the Complaints

The Supreme Court determined that the complaints were fundamentally flawed. According to the provisions in Rule 140 of the Rules of Court, administrative proceedings against judges require verified complaints supported by affidavits from individuals with personal knowledge of the claims. The Court found that the handwritten letters submitted by the complainants lacked verification and substantive evidence.

Burden of Proof and Legal Standards

The burden lies with the complainants to provide substantial evidence supporting their allegations. The standard for administrative complaints necessitates a level of proof beyond mere conjecture. The Cour

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