A.M. No. R-66-RTJ March 18, 1988
The Consolidated Bank and Trust Corporation (Solidbank) vs. Hon. Dionisio M. Capistrano, Presiding Judge, RTC, Pasay City, Branch CXVI

FACTS

The administrative complaint stemmed from the respondent judge’s handling of Civil Case No. 9837-P for damages. The plaintiffs (Nation’s Knitting Enterprises, et al.) sued Solidbank, its counsel, and guards for damages allegedly arising from the enforcement of a writ of attachment issued in a separate case (Civil Case No. 9069-P). Instead of filing an answer, the defendants filed a motion to dismiss, arguing the claim should be litigated in the main case where the attachment issued. Judge Capistrano, in an order dated April 20, 1983, deferred resolution of the motion to dismiss until after trial. The defendants filed a motion for reconsideration and a motion for extension to file an answer. On June 23, 1983, the judge issued a resolution declaring the motion for reconsideration “not filed” and refusing the extension, based on his interpretation of procedural rules. He simultaneously denied a motion to consolidate the case with the main attachment case.
On June 27, 1983, upon plaintiffs’ motion, Judge Capistrano declared the defendants in default, as their answer (filed on July 6, 1983, within the period they had sought an extension for) was not yet filed. He then allowed ex parte presentation of evidence and subsequently rendered a default judgment on August 18, 1983, awarding massive damages totaling over P7.7 million against the defendants. This judgment was later reversed on appeal, with the appellate court finding it “completely unfair and unwarranted.”

ISSUE

Whether the respondent judge’s actions constitute serious misconduct warranting disciplinary action.

RULING

Yes. The Supreme Court found Judge Capistrano guilty of serious misconduct and dismissed him from service. The legal logic rests on the application of the doctrine of res ipsa loquitur (the thing speaks for itself), where the actions on their face demonstrate gross incompetence, ignorance of the law, or misconduct, making a formal investigation unnecessary. The Court scrutinized his procedural rulings. His interpretation of the rules to disallow a motion for reconsideration of an order deferring a motion to dismiss and to refuse a motion for extension was erroneous; such interlocutory orders are subject to reconsideration, and motions for extension are discretionary. More egregiously, he declared the defendants in default and proceeded with an ex parte hearing while their motion for extension was effectively pending and before the expiration of the very extension period they had sought. This precipitous declaration of default, followed by a trial and a judgment awarding unconscionably high damages without hearing the defendants’ side, evidenced a persistent refusal to consider the merits of their defenses. The totality of these acts—the erroneous procedural denials, the rush to default, and the rendering of a patently excessive judgment—could not be explained by good faith or mere error. They demonstrated bad faith, bias, and a lack of integrity, constituting serious misconduct that eroded public faith in the judiciary. The Court held such oppressive abuse of judicial process demands severe corrective discipline to uphold judicial standards.