A.M. No. RTJ-09-2204; October 26, 2009
Juan Pablo P. Bondoc, Complainant, vs. Judge Divina Luz P. Aquino-Simbulan, Respondent.

FACTS

Complainant, former Representative Juan Pablo P. Bondoc, charged respondent Judge Divina Luz P. Aquino-Simbulan with partiality, gross ignorance of the law, and gross misconduct in handling Criminal Case Nos. 12726-12728 for violations of R.A. 3019 and falsification against spouses Salvador and Flordeliz Totaan. The complainant alleged that during pre-trial, the judge privately suggested a settlement to avoid the accused’s administrative suspension, despite having issued the suspension order herself. He further claimed the judge exhibited bias by persistently “fast-tracking” the trial for the accused’s benefit, humiliating his private prosecutor, Atty. Lanee Cui-David, in open court, and inactively implementing the suspension order. The bias allegedly culminated in the judge granting the accused’s demurrer to evidence and dismissing the cases.
In her defense, the respondent judge denied all allegations of partiality. She asserted that her conference with counsel was to clarify case issues, not broker a settlement. She maintained that her directive for weekly hearings was a standard practice to expedite all cases, not favor the accused. She placed the onus for implementing the suspension order on the prosecution and justified her actions during trial as within her discretion to control proceedings.

ISSUE

Whether respondent Judge Divina Luz P. Aquino-Simbulan is administratively liable for the acts complained of.

RULING

The Supreme Court DISMISSED the administrative complaint against the judge for lack of merit. The Court found that the complainant failed to substantiate the charges with clear and convincing evidence. The allegations of partiality based on the judge’s actions—such as suggesting a settlement, scheduling hearings, and ruling on the demurrer to evidence—were within the judge’s legitimate discretion in managing court proceedings. Judicial discretion, absent proof of arbitrariness or bad faith, is not a ground for administrative sanction.
The Court emphasized that a judge’s order or decision, even if erroneous, is not necessarily indicative of bad faith, malice, or corruption. Administrative liability requires proof of gross ignorance, fraud, dishonesty, or corruption, which was not established. The complaint appeared to stem from the complainant’s dissatisfaction with the dismissal of the criminal cases, a matter more appropriately addressed through judicial appeals rather than an administrative proceeding. The Court warned against using administrative complaints as tools to harass judges for their judicial actions.