A.C. No. 3091. May 5, 1989. ARSENIO REYES, complainant, vs. ATTY. DANTE TINGA, respondent.
FACTS

This administrative case originated from Civil Case No. 808-R, where respondent Atty. Dante Tinga was counsel for the plaintiffs. A 1970 trial court decision ordered the defendants, including complainant Arsenio Reyes, to pay attorney’s fees and litigation expenses. This judgment was affirmed by the Court of Appeals in 1979 and became final. In 1981, a writ of execution was issued, and the appointed Special Sheriff reported that Atty. Tinga collected the monetary award as authorized.
In 1987, Reyes filed this complaint seeking Tinga’s suspension from law practice. He alleged that Tinga unlawfully collected attorney’s fees, acted as a private sheriff in connivance with court personnel, and improperly pocketed the fees instead of depositing them with the clerk of court. The Supreme Court dismissed the complaint for lack of merit on December 9, 1987, finding that Tinga’s collection was a lawful implementation of a final judgment and writ of execution, and that the claim regarding deposit with the clerk of court was baseless. Reyes’s motion for reconsideration was denied on February 3, 1988.
Subsequently, Reyes filed a series of pleadings and letters, including motions to include Tinga’s law firm as additional respondents and allegations of fraud and non-compliance. He also submitted documents complaining against a different government official to the Ministry of Justice. The Court consistently noted these submissions without action, citing the finality of the dismissal.

ISSUE

Whether the Supreme Court’s act of merely noting the complainant’s subsequent pleadings and letters, after the final dismissal of the administrative complaint, constitutes a scandalous disposition, bias, or a violation of law.

RULING

The Supreme Court held that its actions were proper and neither scandalous nor biased. The legal logic is anchored on the doctrine of finality of judgments and the proper scope of judicial review in administrative matters. The Court had already rendered a final resolution on the merits, dismissing the complaint because the respondent’s actions were clearly authorized by a final and executory judgment and a corresponding writ of execution. The complainant’s core allegations were without legal basis.
Once a decision becomes final, it puts an end to litigation. The series of Resolutions that merely “noted” the complainant’s subsequent filings were the only appropriate actions, as the Court explicitly stated that the dismissal was final and the motion for reconsideration had been denied. The Court could have opted to expunge these superfluous pleadings. The allegation of bias is unfounded; judicial decisions are rendered with objectivity and impartiality. Furthermore, the Court did not violate Presidential Decree No. 27 or its implementing circular, as these laws are irrelevant to the subject administrative complaint, and the annexed letters were addressed to a different government agency entirely. The complaint was dismissed with finality, and no further pleadings were to be entertained.