Adante v. Cajayon
REITERATIONFacts
The Antecedents: Sylvia Adante and Lucena Ofendoreyes filed separate letter-complaints with the Office of the Ombudsman alleging that Atty. Dorothy Cajayon and Court of Appeals Associate Justice Jane Aurora C. Lantion were engaged in the "selling" of favorable decisions in the Court of Appeals, Cagayan De Oro City (CA-CDO). Adante claimed the illicit activity was "intimated" to her, while Ofendoreyes requested an investigation into the purported partnership between the respondents. Procedural History: The Office of the Ombudsman referred the letter-complaints to the Supreme Court in November 2016. The Court subsequently referred the matters to the Office of the Court Administrator (OCA) for study and consolidation. The OCA recommended consolidation but noted that the complaints were unverified, lacked supporting affidavits from persons with personal knowledge, and were bereft of substantiating documents. The Petition: The administrative matters were consolidated to determine whether the respondents should be held liable for the alleged "systematic practices of corruption." The complainants essentially relied on hearsay and bare allegations, failing to provide direct evidence or comply with the formal requirements for administrative complaints against lawyers and judges under the Rules of Court.
Issue(s)
Whether the unverified letter-complaints, based on hearsay and lacking supporting evidence, are sufficient to hold Atty. Cajayon and Justice Lantion administratively liable.
Ruling
WHEREFORE, the complaints are DISMISSED.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the complaints must be dismissed for failure to comply with the formal and substantive requirements of the Rules of Court. Under Rule 139-B, Section 1 (for lawyers) and Rule 140, Section 1 (for judges and justices), administrative complaints must be verified and supported by affidavits of persons who have personal knowledge of the facts therein alleged and/or by such documents as may substantiate said facts. The Court noted that the letter-complaints in this case were indisputably unverified and lacked any supporting affidavits or documents. Furthermore, Section 2 of Rule 140 explicitly mandates the dismissal of a complaint if it is found insufficient in form and substance. The Court emphasized that in administrative proceedings, the burden of proof rests on the complainant to substantiate charges by substantial evidence. Since the complainants relied on hearsay—specifically Adante's claim that the offense was merely "intimated" to her—the evidence failed to meet the required quantum of proof. Applying the principle in Re: Verified Complaint dated July 13, 2015 of Umali, Jr. v. Hernandez, the Court held that hearsay must be supplemented and corroborated by non-hearsay evidence to be considered substantial. Consequently, the respondents are not obliged to prove their defense, and the presumption that they have regularly performed their duties prevails.
Main Doctrine
The Court reiterates that administrative complaints against lawyers and members of the judiciary must strictly comply with the verification and evidentiary requirements set forth in Rules 139-B and 140 of the Rules of Court. A complaint must be supported by affidavits of persons with personal knowledge or by documents substantiating the allegations to overcome the presumption of regularity in the performance of official duties. Hearsay evidence alone is insufficient to meet the quantum of substantial evidence required in administrative proceedings. Failure to meet these formal and substantive requirements warrants the outright dismissal of the administrative matter.