Sunday, March 20, 2016

Case digest: Secretary Justice vs. Catolico


68 SCRA 62
Secretary Justice vs. Catolico

FACTS:
Two administrative complaints and four charges of “serious misconduct and gross disregard of law” were formulated against Judge Alfredo Catolico.
The first complaint concerned that of the naturalization of 50 naturalized citizens which the the respondent declared the oath taking of the petitioners null and void. The second and third complaints which relate to respondent’s dismissal of the cases which have not been tried for more than thirty days and refusal to recognize not only the authority of the Court to authorize the continuation of the corresponding proceedings but also the personality of the Clerk of this Court to transmit to him the pertinent resolutions of the Court. The fourth complaint regarding the respondents alleged bias and prejudice either in his questioning of the witnesses or in acquitting the accused.
Respondent claims that all his impugned actuations were motivated by his desire to comply with the rules and the law and, most of all, the best interests of justice which require the speedy and expeditious disposition of cases. Respondents plead that “if at all there was any error committed it is of the mind rather than the heart”
ISSUE:
Whether or not the respondent acted with “serious misconduct and gross disregard of law” in the four complaints charged against him.
RULING:
For the obvious reason that all the facts involved in the first three complaints relate to matters of record in the proceedings in this Court in which respondent had been duly heard, no further administrative proceedings were held after respondent filed his answer.
In the first charge, the Court has, in a way, admonished the respondent, adding that they “should not lose the proper judicial perspective, and should see to it that in the execution of their sworn duties they do not overstep the limitations of their power as laid down by statute and by the rules of procedure”
With reference to the second and third charges of the Secretary, the Court had already reprimanded respondent for his offense for his refusal to “apply the law” as interpreted by the tribunal.
Anent the fourth charge, the report of the investigator is to the effect that the actuations of respondent complained of by Mrs. Olaes were not due to any improper or personal motive and were just the result of the innocuous eccentricities and odd ways and ideas of respondent which could not be categorized as serious misconduct nor deserving of any heavier sanction than admonition.
While the Court was awaiting said report, however, in a letter dated April 17, 1975, respondent informed the Court that His Excellency, President Ferdinand E. Marcos had accepted his resignation effective January 11, 1974, “without prejudice to his receiving whatever rights he may be entitled to under the retirement and other existing laws.” Premises considered, and in line with the established policy regarding similar situations wherein the President has accepted resignations without prejudice to the grant of legally possible retirement benefits thus rendering administrative cases pending against the official concerned, moot and academic, the Court resolved to DISMISS the cases against respondent.

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