Rizalado v. Bollozos
REITERATIONFacts
The Antecedents: Four administrative cases were consolidated, all stemming from G.R. No. 188427 concerning Civil Case No. 92-368 and Civil Case No. 92-409. The Supreme Court affirmed the Court of Appeals' decision, which ordered Reuben Guzman to reimburse rentals and make an accounting. The decision became final and executory on September 14, 2010. Procedural History: Guzman, et al., through counsel, filed a Motion for Execution. Respondent Judge Gil G. Bollozos issued a Joint Order dated July 14, 2011, ordering Guzman, et al. to make an accounting. Complainant Oscar C. Rizalado alleged undue delay and inconsistency of this order with the CA Decision. Rizalado also disputed the Clerk of Court's report and recommendation for a commissioner. Respondent Judge claimed the delay was due to multiple motions filed by different counsels for Guzman, et al., and Rizalado's own actions. He also cited legal issues regarding estate taxes and the need for an administrator and accountant before releasing funds. He issued a Joint Order dated December 5, 2011, granting the motion for execution. Rizalado filed further complaints alleging the July 14, 2011 Joint Order amended the judgment and that the nomination of an administrator/accountant was an alteration. Another complaint questioned the January 31, 2011 Order holding in abeyance a motion to withdraw deposits, alleging ignorance of the Rules of Court. Guzman, et al. filed a complaint alleging delay, protection of opposing counsel, and failure to hold Reuben in contempt. They also questioned the order to pay estate tax as premature. Respondent Judge denied these allegations, stating that contempt motions should be filed properly and that estate tax payment is a prerequisite for rental release. Rizalado filed another complaint alleging bribery and alteration of dates in the motion for execution, and failure to cite Reuben in contempt. Respondent Judge denied knowledge of bribery and date alteration, attributing delay to Guzman, et al.'s refusal to assist the sheriff in serving the writ. He explained the July 24, 2011 Joint Order was for accounting due to missing ORs, and contempt could only be addressed after writ service. The appointment of a commissioner was deemed necessary for accounting. The Petition: The consolidated administrative cases alleged undue delay, partiality, gross ignorance of the rules, and bias against respondent Judge Bollozos. Oscar C. Rizalado also filed multiple complaints related to the same case.
Issue(s)
Whether respondent Judge Gil G. Bollozos committed undue delay, partiality, gross ignorance of the rules, or bias in the disposition of the cases related to G.R. No. 188427. Whether Oscar C. Rizalado is guilty of contempt of court for filing multiple administrative complaints against the respondent Judge.
Ruling
The administrative complaints against respondent Judge Gil G. Bollozos are DISMISSED for lack of merit. Complainant Oscar C. Rizalado is found GUILTY of contempt of court and ORDERED to pay a FINE of ₱20,000.00, with a STERN WARNING against repetition.
Ratio Decidendi
On the administrative complaints against respondent Judge: The Court finds that the charges of bias and partiality against the respondent Judge were not substantiated. Complainants failed to present clear and convincing evidence to prove that the respondent Judge was motivated by bias, bad faith, or partiality in the disposition of the cases. The Court reiterated the principle that administrative proceedings are not a substitute for available judicial remedies. If the complainants believed that the respondent Judge's issuances were irregular, they should have availed themselves of the appropriate judicial remedies, such as motions for reconsideration, appeals, or special civil actions like certiorari, prohibition, or mandamus. Resorting to administrative complaints without exhausting these judicial remedies is improper. The Court also found the respondent Judge's explanation for any delay meritorious, considering the multiple motions filed by the parties' counsels. The respondent Judge had already granted the motion for execution in his December 5, 2011 Order. Therefore, the administrative complaints were dismissed for lack of merit. On the charge of contempt against Oscar C. Rizalado: The Court concurs with the Office of the Court Administrator's (OCA) recommendation to find Oscar C. Rizalado guilty of contempt of court. Rizalado indiscriminately and repetitively filed several administrative complaints against the respondent Judge, all related to the same case and alleging similar grounds. This conduct resulted in confusion due to the multiplicity of actions docketed before the OCA. The Court noted Rizalado's previous transgression and penalty in another case where he was fined for unjustified attacks against judges and ordered arrested for non-payment. Consequently, the Court increased the fine to ₱20,000.00, with a stern warning that repetition of the offense would be dealt with more severely.
Main Doctrine
Administrative complaints against judges for alleged errors in the disposition of cases are not the proper remedy when judicial remedies are available. Such complaints must be substantiated by clear and convincing evidence, and bare allegations of bias and partiality are insufficient. Repeatedly filing administrative complaints without exhausting judicial remedies may constitute contempt of court.