A.M. No. 1988-CAR November 7, 1979
ALFREDO NALDA, QUIRICO CABRERA and PATROCINIO PALANOG, as counsels for twenty-eight complainants, vs. JUDGE PASTOR P. REYES, Court of Agrarian Relations, Pasig, Metro Manila, respondent.

FACTS

Attorneys Alfredo Nalda, Quirico Cabrera, and Patrocinio Palanog, representing twenty-eight complainants, filed an administrative complaint against Judge Pastor P. Reyes of the Court of Agrarian Relations. The complaint, dated July 31, 1978, accused the respondent judge of ignorance of the law, abuse of authority or grave abuse of discretion, and violation of specific decrees and laws including P.D. 946, P.D. 815, and R.A. 3844. In his comment, Judge Reyes defended his actions and characterized the complaint as malicious and intended to harass the court.
Subsequently, the complainants, through their counsel Atty. Palanog, filed a petition dated October 12, 1978, and a supplemental petition dated October 24, 1979, seeking the dismissal of their own complaint. They cited several grounds, including that the complaint was based on a misapprehension of facts, that Judge Reyes had acted with honesty, impartiality, and dedication in handling their cases, and that he had successfully facilitated amicable settlements in the very agrarian cases (CAR Case Nos. 1293-R and 1332) that had given rise to the administrative charges. They stated their full faith and confidence in him, rendering the complaint moot and academic.

ISSUE

Whether the administrative complaint against Judge Pastor P. Reyes should be dismissed based on the complainants’ subsequent withdrawal and retraction of their allegations.

RULING

Yes, the administrative case is dismissed. The Supreme Court, adopting the recommendation of the Court Administrator, found the dismissal to be warranted. The legal logic rests on the principle that the withdrawal of a complaint by the complainants themselves, coupled with a positive retraction of the charges and an affirmation of the judge’s integrity and competence, significantly undermines the basis for pursuing the administrative action.
The Court considered the substantive reasons provided in the petitioners’ withdrawal. They explicitly recanted their initial accusations, attributing them to “misapprehension of facts and/or inaccurate reports.” More importantly, they attested to the respondent judge’s proper judicial conduct, his role in settling the underlying cases, and their restored confidence in his judiciousness. This voluntary desistance and positive vindication of the respondent judge’s performance effectively negated the prima facie grounds for the charges of ignorance of the law or abuse of authority. The Court, in line with a precedent cited in the memorandum (Administrative Case No. 1770), recognized that where the complainants themselves seek dismissal following an amicable resolution of the underlying dispute, and where no compelling public interest demanding further investigation is apparent, dismissing the case is appropriate. The ruling closes the matter without a finding on the merits of the original allegations, as the complainants’ own actions rendered the case moot.