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 award was affirmed by the Court of Appeals in 1979. 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, alleging the collection violated Article 2208 of the Civil Code and an Administrative Circular, and that Tinga 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’ 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 respondent and allegations of fraud, which the Court merely “noted” in successive resolutions. Reyes then accused the Second Division of bias and of violating Presidential Decree No. 27 and its implementing circular by noting his submissions without action.

ISSUE

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

RULING

The Court ruled that its actions were proper and justified. The legal logic is anchored on the doctrine of finality of judgments and the proper scope of judicial review in administrative matters. The core administrative complaint had been resolved with finality by the Resolutions dated December 9, 1987 (dismissal) and February 3, 1988 (denial of reconsideration). These resolutions correctly held that the respondent lawyer’s actions were a legitimate enforcement of a final and executory court decision and writ of execution; thus, no ethical violation occurred.
Consequently, all pleadings filed by the complainant after the denial of his motion for reconsideration were superfluous. The Court’s action of “noting” them was the most appropriate procedural course, as the matter was already closed. The Court explicitly stated it could have opted to expunge these pleadings. This procedural handling does not demonstrate bias or scandal but rather adherence to judicial economy and the finality of decisions. Furthermore, the allegation that noting the pleadings violated Presidential Decree No. 27 (on agrarian reform) is wholly without merit, as the decree is irrelevant to the subject of the administrative case, which concerned the collection of a judgment award. The Court emphasized that dissatisfaction with a ruling does not justify accusations of impropriety, as decisions are rendered with objectivity and impartiality. The dismissal of the administrative case was declared final, and no further pleadings would be entertained.