G.R. No.: A.M. No. MTJ-05-1601. Date: August 11, 2005.
Case Parties/Title: Mercedes G. Duduaco, Complainant, vs. Judge Lily Lydia A. Laquindanum, Municipal Circuit Trial Court, Kabacan, North Cotabato, Respondent.

FACTS

On March 4, 2002, complainant Mercedes G. Duduaco, manager of Toyota Service Center in Davao City (Toyota-Davao), filed an administrative complaint against respondent Judge Lily Lydia A. Laquindanum for grave misconduct, abuse of judicial office, and/or gross ignorance of the law. The complaint stemmed from an incident on June 23, 2001, when respondent brought her vehicle to Toyota-Davao for repairs covered by insurance. Toyota-Davao employees (Jeson M. Garao, Randy A. Saragoza, and Vicente U. Yñez) demanded payment of a deductible franchise before releasing the vehicle. Respondent initially refused, insisting the insurance company should pay. According to the employees, respondent became angry, raised her voice, identified herself as a judge, and demanded preferential treatment to see the manager. She eventually paid under protest but refused to sign a blank “Release of Claim with Subrogation” form, after which she left without the car. On July 4, 2001, respondent filed a Replevin case against Toyota-Davao. On July 19, 2001, Yñez, Saragoza, complainant Duduaco, and an insurance company representative visited respondent in her office to apologize. In her Comment, respondent denied abusing her judicial authority. She claimed she requested a written demand for the deductible as proof for a refund claim, paid under protest, and refused to sign only a blank release form. She alleged it was Yñez who became angry and took back the form, leaving her stranded until evening, after which she wrote a letter to complainant and left without her car.

ISSUE

Whether respondent Judge Lily Lydia A. Laquindanum is administratively liable for grave misconduct, abuse of judicial office, and/or gross ignorance of the law based on the June 23, 2001 incident at Toyota-Davao.

RULING

The Supreme Court DISMISSED the administrative complaint against respondent Judge for lack of merit. The Court held that in administrative proceedings, the burden of proof lies with the complainant, and charges must be proven beyond reasonable doubt. The Court found that respondent’s refusal to pay the deductible franchise without a written demand and her refusal to sign a blank release form were exercises of her legal rights, not acts of misconduct, abuse of authority, or gross ignorance of the law. Signing a blank form would have waived her right to claim a refund. The Court noted that complainant Duduaco admitted during the investigation that she was absent during the incident and had no personal knowledge, yet she verified the complaint as true. The Court also found the complaint was filed eight months after the incident and only after respondent had filed and won a replevin case, indicating it was a retaliatory, baseless suit filed in bad faith to harass respondent and object to her judicial appointment. Consequently, the Court Fined complainant Mercedes G. Duduaco in the amount of P10,000.00 for filing a baseless and unfounded administrative suit.