AM 17 03 03 CA; (July, 2017) (Digest)
A.M. No. 17-03-03-CA/IPI No. 17-258-CA-J EN BANC July 11, 2017
RE: LETTER OF RAFAEL DIMAANO and RE: UNSWORN COMPLAINT OF ROSA ABDULHARAN, both against ASSOCIATE JUSTICE JANE AURORA C. LANTION and ATTY. DOROTHY S. CAJAYON
FACTS
Two separate letter-complaints were filed by Rosa Abdulharan and Rafael Dimaano before the Office of the President and the Department of Justice, respectively, which were subsequently referred to the Supreme Court. The complainants charged Associate Justice Jane Aurora C. Lantion of the Court of Appeals, Cagayan de Oro City, and Atty. Dorothy S. Cajayon with engaging in a syndicate to “sell” favorable decisions. Abdulharan alleged that Atty. Cajayon solicited money from litigants with pending cases, promising a favorable decision from Justice Lantion for the right price. Dimaano similarly requested an investigation into the alleged consistent and incessant activities of this purported syndicate.
In their respective Comments, both respondents vehemently denied the allegations. Atty. Cajayon asserted she did not know any of the complainants, had never handled or been consulted on any case before Justice Lantion’s division, and had no professional or personal association with the Justice beyond being former law school underclassmates. Justice Lantion denied knowing Atty. Cajayon, clarified her brief two-and-a-half-year assignment in Cagayan de Oro ended in 2009, and characterized the complaints—filed nearly eight years after her transfer—as baseless, unsubstantiated, and replete with sweeping generalizations.
ISSUE
Whether the administrative complaints for serious misconduct (selling judicial decisions) against Justice Lantion and Atty. Cajayon have sufficient factual and legal basis to warrant disciplinary action.
RULING
The Supreme Court DISMISSED the complaints for utter lack of merit. The Court emphasized that in administrative proceedings, the burden of proof lies with the complainant, and charges must be substantiated by substantial evidence. The Court found the accusations to be based purely on unverified, unsworn letters containing mere suspicions, conjectures, and generalizations without any corroborating evidence. The complainants failed to present specifics such as case titles, docket numbers, dates of the alleged transactions, or any form of documentary or testimonial proof.
The Court highlighted the gravity of an accusation of selling decisions, which attacks the very integrity of the judiciary, and such a charge must be examined with a discriminating eye. While the Court is duty-bound to weed out unscrupulous officials, it is equally obligated to protect judges and lawyers from unfounded suits that serve only to harass. Where, as here, the allegations rest on mere supposition and are categorically denied with plausible explanations by the respondents, the complaint cannot prosper. The absence of any factual foundation rendered the charges baseless, leading to their dismissal. The resolution serves to shield members of the judiciary and the bar from baseless administrative charges that disrupt the orderly administration of justice.