G.R. No. A.M. No. 203-J & A.M. No. 625-CFI November 18, 1975
THE SECRETARY OF JUSTICE and FERMINA OLAES, complainants, vs. JUDGE ALFREDO CATOLICO, respondent.

FACTS

Two consolidated administrative complaints were filed against Judge Alfredo Catolico. The first, by the Secretary of Justice, contained three charges. These stemmed from the judge’s 1965 motu proprio declaration nullifying the oath-taking in over fifty naturalization cases, during which he delivered a lengthy, intemperate diatribe in open court, particularly castigating a naturalized citizen with derogatory epithets. The other charges involved his refusal to continue trying cases he deemed dormant, and his disrespectful disregard of Supreme Court resolutions transmitted by the Clerk of Court, whom he refused to recognize as a proper conduit of the Court’s authority.
The fourth complaint was filed by Fermina Olaes, widow in a homicide case. She alleged the judge rushed the trial to acquit the accused before his retirement, acted as prosecutor by aggressively questioning a witness for two hours, and displayed bias through bullying and ridicule, including asking if the witness was examined by a veterinarian.

ISSUE

Whether respondent Judge Catolico should be held administratively liable for serious misconduct and gross disregard of law based on the consolidated charges.

RULING

The Supreme Court found the respondent’s actions, particularly those under the first three charges, constituted gross disrespect for the law and the judiciary. His motu proprio actions in the naturalization cases were reckless, and his vitriolic language from the bench was utterly improper and unbecoming of a magistrate. His refusal to acknowledge the Clerk of Court’s authority to transmit Supreme Court resolutions was a gross disrespect for the Court itself, demonstrating a failure to appreciate fundamental court procedures and the principle of authority vested in the Chief Justice.
Regarding the fourth charge, the investigating justice found the judge’s odd behavior during the homicide trial, while eccentric and improper, was not motivated by corrupt intent but by a misguided judicial temperament. However, while the Court was reviewing the case, Judge Catolico submitted a resignation dated January 11, 1974, which had been accepted by the President without prejudice to retirement benefits. Following established policy, the acceptance of the resignation rendered the administrative cases moot and academic. Consequently, the Court dismissed the complaints.