Reyes v. Tinga
REITERATIONFacts
The Antecedents: Complainant Arsenio Reyes filed a letter-complaint against Atty. Dante Tinga. The complaint stemmed from a civil case where Atty. Tinga represented some plaintiffs. A decision was rendered ordering defendants, including Complainant Reyes, to pay P5,000.00 as attorney's fees and P2,000.00 as expenses of litigation. This decision was affirmed by the Court of Appeals, and entry of judgment was made on January 15, 1979. A writ of execution was issued by the Trial Court on October 3, 1979, authorizing the withdrawal of the supersedeas bond of P6,900.00 as payment for attorney's fees and expenses of litigation. A Special Sheriff was appointed to execute the writ. The Sheriff's Return indicated that Atty. Dante Tinga withdrew P4,100.00 from the Clerk of Court and P2,800.00 was garnished from a bank. Procedural History: Complainant Reyes filed a Petition for suspension of Atty. Tinga, alleging collection of attorney's fees and expenses in violation of law, acting as a sheriff illegally with others, and pocketing legal fees instead of depositing them. The Supreme Court dismissed the administrative complaint for lack of merit on December 9, 1987, finding that the collection was in implementation of the court's decision and authorized by the writ of execution, and that the contention regarding deposit was baseless. Complainant's Motion for Reconsideration was denied on February 3, 1988, for lack of merit. Subsequently, Complainant filed several pleadings, including motions to include other respondents, manifestations alleging fraud, letters submitting factual background, requests to attach affidavits, and letters submitting annexes consisting of complaints against an Administrator of the National Land Titles and Deeds Registration Administration. The Court noted these pleadings without action, reiterating that the administrative complaint had been dismissed and the motion for reconsideration denied. The Petition: Complainant Reyes' letter of February 10, 1989, addressed to the Office of the Chief Justice, complained that the Court's actions of noting without action subsequent pleadings were a violation of Presidential Decree No. 27 and Circular No. 31, and that the Court's disposition showed scandalous bias.
Issue(s)
Whether the Supreme Court's noting of subsequent pleadings after the dismissal of the administrative complaint and denial of the motion for reconsideration constitutes a "scandalous disposition" or "bias". Whether the Court's action of noting Annexes "A" and "B" violated Presidential Decree No. 27 and its implementing Circular No. 31.
Ruling
The Supreme Court denied further pleadings and reiterated the dismissal of the administrative complaint. The Court held that its act of noting the series of pleadings filed by the complainant was not a "scandalous disposition" nor a showing of "bias." The Court emphasized that no other proper action could have been taken since the administrative complaint had been dismissed for lack of merit and the motion for reconsideration denied. The Court further stated that since the dismissal had become final, no further pleadings need have been entertained. The Court also found no violation of Presidential Decree No. 27 or its implementing Circular No. 31 in noting the annexes, as these enactments were irrelevant to the administrative complaint and the annexes pertained to a separate matter addressed to the Ministry of Justice.
Ratio Decidendi
On the issue of "scandalous disposition" or "bias" and the Court's action on subsequent pleadings: The Court clarified that its act of "noting" the various pleadings filed by the complainant after the dismissal of the administrative complaint and the denial of the motion for reconsideration was not indicative of "scandalous disposition" or "bias." The Court explained that such action was the only proper course given that the administrative complaint had already been dismissed for lack of merit. The Court further underscored that once the dismissal of an administrative complaint becomes final, no further pleadings need to be entertained, and the Court could have even ordered them expunged. The Court's consistent reiteration in its resolutions that the complaint was dismissed and the motion for reconsideration denied served to inform the complainant of the finality of the Court's action. The Court addressed the complainant's assertion that the Court's disposition was scandalous and biased. It stated that a litigant's failure to succeed in their cause does not justify such accusations. The Court affirmed that its decisions are always rendered with strict objectivity and impartiality, guided solely by truth and justice. The Court's consistent denial of the administrative complaint and the motion for reconsideration, based on lack of merit, demonstrated adherence to these principles rather than bias. On the alleged violation of Presidential Decree No. 27 and Circular No. 31: The Court found no violation in its action of "simply noting" Annexes "A" and "B" submitted by the complainant. The Court reasoned that Presidential Decree No. 27 and its implementing Circular No. 31 were clearly irrelevant and immaterial to the administrative complaint at hand. Furthermore, the Court pointed out that Annexes "A" and "B" themselves referred to letters-complaint against the Administrator of the National Land Titles and Deeds Registration Administration and were addressed to the Ministry of Justice, not to the Supreme Court. Therefore, the Court's act of noting these documents had no bearing on the validity or applicability of the said decree and circular to the administrative case.
Main Doctrine
A litigant's failure to succeed in a cause does not justify accusations of scandal or bias; decisions are rendered with objectivity and impartiality based on truth and justice. Once an administrative complaint is dismissed for lack of merit and the motion for reconsideration is denied, no further pleadings need be entertained.