View full case

PROSEC. JORGE D. BACULI v. JUDGE MEDEL ARNALDO B. BELEN

FACTS:

State Prosecutor II Jorge D. Baculi filed two administrative complaints against Judge Medel Arnaldo B. Belen of the Regional Trial Court (RTC), Branch 36 in Calamba City, Laguna. The complaints, docketed as A.M. No. RTJ-09-2179 and A.M. No. RTJ-10-2234, were consolidated upon the recommendation of the Office of the Court Administrator.

In A.M. No. RTJ-09-2179, Baculi alleges that Judge Belen issued unlawful and unjust orders in relation to a case pending in the RTC. Baculi claims that Judge Belen dismissed a qualified theft case and subsequently found Baculi guilty of contempt of court. Baculi also alleges that the contempt cases filed against him were motivated by personal resentment and hatred. Baculi filed a motion for reconsideration and appealed the contempt decisions, but Judge Belen ordered Baculi to post a supersedeas bond, which Baculi questioned.

In A.M. No. RTJ-10-2234, Baculi makes similar allegations against Judge Belen relating to a different case, People of the Philippines v. Jenelyn Estacio. Baculi argues that he was not given a chance to explain his participation in the case and that Judge Belen's actions were in bad faith.

The cases were referred to the Office of the Court Administrator (OCA) for investigation. The OCA found the complaints partially meritorious, noting that Baculi failed to question the decisions through proper judicial channels. However, it also found that Judge Belen failed to follow the proper procedure for the contempt proceedings. The OCA recommended that Judge Belen be found guilty of gross ignorance of the law and be fined Php 30,000, with a warning of a more severe penalty for similar offenses in the future.

ISSUES:

  1. Whether administrative complaints can substitute for lost judicial remedies in contempt proceedings.

  2. Whether Judge Belen failed to follow the proper procedure in the contempt proceedings.

  3. Whether there was proof of bad faith, evil motive, or corrupt intention on the part of Judge Belen.

  4. Whether or not the judge can be held administratively liable for errors committed in good faith.

  5. Whether the judge followed the proper procedure in citing the complainant in contempt of court.

  6. Whether the court properly initiated indirect contempt proceedings against the respondent.

  7. Whether the respondent was afforded the opportunity to present his defense.

RULING:

  1. Administrative complaints cannot substitute for lost judicial remedies in contempt proceedings.

  2. Judge Belen did not fail to follow the proper procedure in the contempt proceedings.

  3. There was no proof of bad faith, evil motive, or corrupt intention on the part of Judge Belen.

  4. No administrative liability can arise on the part of the judge if the contempt proceedings followed the required procedure. The complainant failed to present evidence of evil or corrupt motives on the part of the judge.

  5. The judge followed the proper procedure in citing the complainant in contempt of court. The orders issued by the judge were in the nature of a show-cause order and directed the respondent to explain why he should not be cited in contempt. These orders are formal charges sufficient to initiate the indirect contempt proceedings.

  6. The court properly initiated the indirect contempt proceedings against the respondent. Indirect contempt proceedings may be initiated by a verified petition or by the court motu proprio. In this case, the court motu proprio initiated the proceedings through a show-cause order.

  7. The respondent was afforded the opportunity to present his defense. In indirect contempt proceedings, the respondent must be given the right to defend himself and have a day in court. The respondent must be given the opportunity to comment on the charges, and there must be a hearing. In this case, the respondent repeatedly filed motions and manifestations to postpone or cancel the hearings, instead of answering the charges against him.

PRINCIPLES:

  • Administrative complaints cannot be used as substitutes for judicial remedies in contempt proceedings.

  • The proper remedies for judgments in direct and indirect contempt proceedings are provided in Rule 71, Sections 2 and 11 of the Rules of Court.

  • Disciplinary proceedings and criminal actions against a judge are not complementary or suppletory to judicial remedies, and should not be used as substitutes for such remedies.

  • Judgments or orders rendered by a court of competent jurisdiction should become final at a definite time fixed by law, and parties should not be permitted to litigate the same issues repeatedly.

  • The mere initiation of contempt proceedings against a complainant does not by itself prove ill motives on the part of the judge.

  • A judge can only be held administratively liable if there is evidence of gross and deliberate error, a perverted judicial mind, or gross ignorance of the law.

  • Not every error committed by a judge warrants administrative sanctions, unless it is a manifestation of bad faith, dishonesty, corruption, or gross ignorance of the law.

  • In indirect contempt proceedings, there are two ways of initiating them: (1) motu proprio by the court; or (2) by a verified petition.

  • When the court initiates the indirect contempt proceedings motu proprio, it has to inform the respondent in writing, in accordance with due process. The written order should be specific enough to inform the respondent about the charges and give them an opportunity to respond.

  • Verified petitions for indirect contempt must comply with the requirements for filing initiatory pleadings and should be docketed, heard, and decided separately from the main case, unless the court orders consolidation.

  • Indirect contempt proceedings may be initiated by a verified petition or by the court motu proprio.

  • In indirect contempt proceedings, the respondent must be given the right to defend himself and have a day in court.

  • The respondent must be given the opportunity to comment on the charges, and there must be a hearing.

  • A respondent in indirect contempt proceedings cannot be blamed if the proceedings conclude without any answer from him or her, if the respondent repeatedly files motions and refuses to address the charges.