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ATTY. NAPOLEON S. VALENZUELA v. JUDGE REYNALDO B. BELLOSILLO

FACTS:

Attorney Napoleon S. Valenzuela filed an Affidavit-Complaint against Judge Reynaldo Bellosillo of Branch 34 of the Metropolitan Trial Court of Quezon City. The complaint alleged that Attorney Valenzuela was hired as counsel for the accused in a criminal case for Violation of B.P. 22. He filed a manifestation requesting the court to allow the accused to post bail. However, Judge Bellosillo allegedly spoke to the accused in his chambers without Attorney Valenzuela present and ordered her to remove him as counsel, suggesting a replacement attorney. The accused later informed Attorney Valenzuela about Judge Bellosillo's order, and he filed a notice of withdrawal as counsel. The complaint claimed that Judge Bellosillo's actions were oppressive, arrogant, and constituted gross misconduct. In his answer, Judge Bellosillo denied the allegations and explained that the accused wanted to change counsel after not liking the idea of being referred to a Public Attorney's Office lawyer. The matter was referred to the Executive Judge of the Regional Trial Court for investigation, report, and recommendation.

ISSUES:

  1. Whether or not respondent Judge Bellosillo violated the constitutional right of the accused to assistance by counsel of her own choice.

  2. Whether or not respondent Judge Bellosillo committed gross misconduct, oppression, and partiality.

RULING:

  1. The Supreme Court found that respondent Judge Bellosillo did not violate the constitutional right of the accused to assistance by counsel of her own choice. The accused voluntarily terminated the services of her counsel and there was no evidence to support the claim that the judge forced the accused to replace her counsel.

  2. The Supreme Court found that there was no sufficient evidence to prove the allegations of gross misconduct, oppression, and partiality against respondent Judge Bellosillo. There was no proof that the judge acted with bias or abused his authority.

PRINCIPLES:

  • The accused has the right to assistance by counsel of their own choice. However, this right may be waived voluntarily by the accused.

  • Allegations of misconduct, oppression, and partiality against a judge must be supported by sufficient evidence to establish the claim. Mere allegations or speculation are not enough to prove such claims.