G.R. No. RTJ-25-099, August 5, 2025
Corpus B. Alzate, Complainant, vs. Hon. Raphiel F. Alzate, Presiding Judge, Branch 1, Regional Trial Court, Bangued, Abra, Respondent.

FACTS

Complainant Judge Corpus Alzate filed an administrative complaint against respondent Judge Raphiel F. Alzate for alleged misconduct and dishonesty related to annulment cases in his court, Branch 58, RTC, Bucay, Abra (RTC-Branch 58). The complainant alleged that RTC-Branch 58 was notoriously known as the “Annulment Capital of the North,” where lawyers filed cases even if parties were not residents, with the respondent disregarding residency requirements. He further averred that the respondent and his wife, Atty. Maria Saniata Liwliwa Gonzales-Alzate, operated as a “conjugal syndicate,” offering “package deals” for quick annulments. Atty. Gonzales-Alzate would initially deal with parties and assign their cases to certain lawyers, after which the respondent would decide in their favor. Assigned lawyers often had no knowledge of or participation in the cases but feared complaining due to other pending cases.
Specific allegations involved two cases: (1) Villanueva v. Villanueva (Civil Case No. 13-764), where the petitioner, a childhood friend of the respondent, allegedly falsely claimed residency in Bucay, Abra, and where Atty. Gonzales-Alzate, after withdrawing as counsel, still appeared in the March 2014 hearing minutes, and (2) Bermudez v. Bermudez (Civil Case No. 14-804), where the counsel of record, Atty. Byrone B. Alzate, allegedly only signed the petition as an accommodation, with the case granted without him presenting witnesses or attending hearings.
The respondent denied all accusations. For Villanueva, he stated the case was filed before his assignment, his wife withdrew upon his assumption, and he submitted affidavits and certifications to prove the petitioner’s residency in Bucay. For Bermudez, he maintained there were no irregularities and submitted an affidavit from Atty. Alzate (First Alzate Affidavit) denying any irregularity and affirming his participation. The complainant, in reply, submitted a photographed copy of the hearing minutes showing Atty. Gonzales-Alzate’s name and a contrary affidavit from Atty. Alzate (Second Alzate Affidavit) stating he was never notified of or attended hearings for Bermudez. The respondent, in rejoinder, attributed the inclusion of his wife’s name in the minutes to staff inadvertence and submitted another original of the First Alzate Affidavit.
The case was referred to the Court of Appeals for investigation. The Investigating Justice found the evidence insufficient to prove the allegations, noting the complainant failed to substantiate claims with substantial evidence. However, the Supreme Court, in a related disbarment case (In re: Alzate), found the respondent and his wife guilty of gross misconduct for operating an annulment scheme, violating the lawyer’s oath and Code of Professional Responsibility.

ISSUE

Whether respondent Judge Raphiel F. Alzate should be held administratively liable for Gross Misconduct, Gross Ignorance of the Law, and violations of the Code of Judicial Conduct based on the allegations of operating an annulment case scheme with his wife.

RULING

Yes, the respondent is administratively liable.
The Supreme Court found the respondent guilty of Gross Misconduct and Gross Ignorance of the Law. The Court adopted the factual findings and conclusions from its prior decision in the disbarment case, In re: Alzate, where it was established that the respondent and his wife operated a scheme to expedite annulment cases for a fee, assigning them to “accommodation lawyers” who did not participate, while the respondent decided the cases favorably. This scheme involved fabricating jurisdictional facts, such as residency, to mislead the court.
The respondent’s actions constituted Gross Misconduct, defined as a transgression of established rules of action through an unlawful or improper motive. His participation in the annulment scheme, which undermined judicial integrity and public confidence, demonstrated a flagrant disregard for ethical standards. Furthermore, his failure to ascertain the true facts of residency before assuming jurisdiction constituted Gross Ignorance of the Law, as it showed a blatant disregard for basic legal rules on venue and jurisdiction in annulment cases.
As a judge, the respondent violated the Code of Judicial Conduct, which requires integrity, independence, and avoidance of impropriety. His actions, done in conspiracy with his wife, eroded public trust in the judiciary. Considering the seriousness of the charges and following precedent, the Supreme Court imposed the penalty of DISMISSAL from service, with forfeiture of all retirement benefits, except accrued leave credits, and with prejudice to reinstatement or appointment to any public office, including government-owned or -controlled corporations. He was also ordered to pay a fine of Two Hundred Thousand Pesos (P200,000.00).