A.M. No. CA-04-38. March 31, 2004.
FRANCISCO GALMAN CRUZ, complainant, vs. JUSTICE PORTIA ALIÑO-HORMACHUELOS, et al., respondents.

FACTS

Complainant Francisco Galman Cruz, a lawyer, was the defendant in an ejectment case filed by the Province of Bulacan. The case was initially handled by then Provincial Attorney Manuel D. J. Syciangco. After Syciangco’s appointment and subsequent inhibition as a judge, the case was eventually assigned to MTC Judge Ester R. Chua-Yu, who decided against Cruz. Cruz appealed to the RTC, where Judge Caesar A. Casanova affirmed the decision. His subsequent petition for review to the Court of Appeals, ponented by Justice Portia Aliño-Hormachuelos, was likewise denied. After the Supreme Court dismissed his final appeal, Cruz filed a petition for annulment of judgment. This was raffled to Judge Renato C. Francisco, who denied a TRO and later inhibited himself. The case was then transferred to Judge Victoria Fernandez-Bernardo, who also denied Cruz’s motions.
Cruz then filed this administrative complaint against all the judges and justice involved, alleging grave misconduct, gross ignorance of the law, and rendering unjust judgments. He specifically charged Judge Syciangco with conflict of interest, Judge Chua-Yu with lack of territorial jurisdiction, and the other respondents for affirming erroneous decisions or denying his motions.

ISSUE

Whether the respondents are administratively liable for their judicial actions in the ejectment case and its subsequent appeals.

RULING

No. The Supreme Court dismissed the complaint for utter lack of merit and found complainant Cruz guilty of contempt of court. The Court emphasized that an administrative complaint is not the proper remedy to assail the correctness of a judge’s decision, which should be addressed through judicial appeals. The respondents’ actions—including Judge Chua-Yu’s designation to try the case, which was a valid assignment by the Executive Judge, and the appellate decisions affirming the lower courts—were all performed within their official jurisdiction and did not constitute gross ignorance of the law or misconduct.
The Court ruled that the complaint was frivolous, harassing, and calculated to malign the respondents’ integrity after Cruz exhausted all judicial remedies and lost. By making unfounded and malicious imputations that degraded the administration of justice, Cruz, as a lawyer, violated his duty to uphold the dignity of the courts. Citing precedents, the Court held that such conduct constitutes contempt. Cruz was fined Twenty Thousand Pesos (₱20,000.00) and sternly warned that a repetition would be dealt with more severely.