Case Summary (A.M. No. RTJ-20-2576)
Allegations Made by the Complainant
Sindon lodged his complaint on October 12, 2017, citing violations of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), Section 5 of Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees), and Section 1 of Rule 137 of the Rules of Court. He alleged that Judge Alzate and Atty. Querrer conspired to give unwarranted benefits to Atty. Gonzales-Alzate by denying his request for documentation related to her notarial commission and suppressing public records. Furthermore, it was claimed that Judge Alzate violated the requirement to recuse himself from considering matters involving his spouse.
Responses from the Respondents
In response to the allegations, Judge Alzate argued that Sindon’s request was suspicious due to inconsistencies in names and lack of details regarding the law firm. He suggested that the complaint against him was motivated by a personal vendetta, as Sindon was allegedly allied with a rival political faction. Atty. Querrer supported Alzate's position, indicating that she acted in accordance with instructions from Judge Alzate while handling the request.
Motion to Withdraw Complaint
On September 10, 2018, Sindon sought to withdraw the complaint, indicating that he did not fully understand the implications of his actions and was coerced by outside influences. The motion raised questions about its effect on the proceedings, specifically whether it could void the jurisdiction of the court over the case.
Office of the Court Administrator's Findings
The Office of the Court Administrator (OCA) evaluated the situation, noting that the request was acted upon within the legally required timeframe, indicating no inaction. It pointed out that the alleged conspiracy of favoritism was not substantiated with evidence. Despite that, the OCA found Judge Alzate liable for acting on his wife's application without recusal, thus recommending appropriate administrative sanctions.
Core Issues
The court addressed several core issues, including the implications of Sindon’s motion to withdraw the complaint, the administrative liability of Judge Alzate and Atty. Querrer, and whether Judge Alzate’s actions constituted a violation of the rules governing judicial conduct.
Rulings on Jurisdiction and Complaint Withdrawal
The court affirmed that Sindon’s withdrawal of the complaint did not affect the court’s jurisdiction, emphasizing the need for accountability among judicial officials beyond personal interest considerations. Administrative liability exists independently of the complainant's intentions or actions.
Findings on Administrative Liability
The court concurred with the OCA's findings regarding t
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Antecedents
- Complainant Samson B. Sindon filed a complaint against Raphiel Alzate, Presiding Judge of RTC-Branch 1, Bangued, Abra, and Atty. Janice Siganay Querrer, Clerk of Court, alleging violations of:
- Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act)
- Section 5 of Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees)
- Section 1 of Rule 137 of the Rules of Court (Disqualification of judges).
- The complaint stemmed from Sindon's request on September 6, 2017, for a copy of an order granting a notarial commission to his wife, Atty. Ma. Saniata Liwliwa Gonzales-Alzate, which was denied by Atty. Querrer, who allegedly suppressed the record.
- Sindon accused Judge Alzate and Atty. Querrer of conspiring to provide unwarranted benefit to Atty. Gonzales-Alzate, failing to act promptly on his request, and Judge Alzate not recusing himself from a case involving his wife.
Responses from Respondents
- In his comment dated September 5, 2018, Judge Alzate claimed:
- Sindon’s request was dubious due to discrepancies in names and the absence of an address.
- The complaint was motivated by harassment, alleging political ties between Sindon and Mayor Jendricks Luna, who was involved in another case against him.
- The notarial commission was granted after his wife met all requirements, as