A.M. No. MTJ-92-718 November 7, 1994
Melencio Parane, complainant, vs. Judge Ricardo A. Reloza, respondent.

FACTS

Complainant Melencio Parane sought assistance from the Office of the Court Administrator (OCA) to expedite the disposition of a forcible entry case submitted for decision in August 1991 before respondent Judge Ricardo A. Reloza of the Municipal Trial Court of Laoang, Northern Samar. The OCA, through several indorsements and a Court En Banc resolution dated November 10, 1992, repeatedly required Judge Reloza to comment on the administrative complaint. He consistently failed to comply with these directives.
Despite a subsequent Court resolution on July 22, 1993, which imposed a fine of P500.00 and reiterated the order to comment, Judge Reloza neither paid the fine nor submitted his comment. The Court, in a resolution dated August 4, 1994, increased the fine to P5,000.00 for gross misconduct and insubordination and granted a final ten-day period for compliance. Judge Reloza received this resolution on August 12, 1994, but again ignored both the payment of the fine and the filing of the required comment.

ISSUE

Whether respondent Judge Ricardo A. Reloza should be held administratively liable for his repeated failure to comply with the lawful directives of the Supreme Court.

RULING

Yes, respondent Judge is administratively liable and is dismissed from service. The Supreme Court emphasized that judges are mandated to obey the orders and processes of the Court without delay. Judge Reloza’s repeated and willful disregard of multiple resolutions—requiring him to comment on the complaint, to show cause, and to pay imposed fines—constitutes gross misconduct and insubordination. His contumacious conduct demonstrated not merely neglect, but a blatant defiance of judicial authority and a clear lack of interest in remaining part of the judiciary.
The legal logic is grounded on the principle that the Court’s administrative authority over judicial personnel must be respected to ensure an orderly and efficient judiciary. Compliance with its directives is not discretionary. By ignoring these orders, Judge Reloza exhibited an utter disrespect for the judicial system, warranting the ultimate penalty. The Court resolved that his actions merited dismissal from service with forfeiture of all benefits and perpetual disqualification from re-employment in any government office, effective upon his receipt of the resolution.