Macalintal v. Teh

Adm. Matter No. RTJ-97-1375 (October 16, 1997)

Atty. Macalintal's complaint led to Judge Teh's dismissal for judicial misconduct and bias.

Facts:

Atty. Romulo B. Macalintal filed a complaint against Judge Angelito C. Teh, the Executive Judge and Presiding Judge of the Regional Trial Court, Branch 87, Rosario, Batangas, regarding his conduct in Election Case No. R-95-001. The case arose when Judge Teh issued a resolution that was unfavorable to Atty. Macalintal's client. Subsequently, Atty. Macalintal filed a petition for certiorari with the Commission on Elections (COMELEC) to contest the resolution. While the petition was pending, Judge Teh actively participated in the proceedings by submitting comments and an urgent manifestation.

In response to Judge Teh's actions, Atty. Macalintal filed a motion to inhibit Judge Teh from further involvement in the case. Instead of addressing the motion, Judge Teh hired his own lawyer and filed an answer to the motion for inhibition, which included a request for Atty. Macalintal to pay him P100,000.00 in attorney's fees and litigation expenses. Judge Teh denied the motion for inhibition, claiming it lacked sufficient legal and factual basis.

The Supreme Court required Judge Teh to comment on the complaint and later treated Atty. Macalintal's letter as an administrative complaint against him. Judge Teh admitted to filing his own pleadings out of respect for the COMELEC's order but failed to act on the motion for inhibition as prescribed by the Rules of Court. The Court noted that Judge Teh's actions demonstrated a lack of understanding of his role and responsibilities as a judge.

Legal Issues:

  1. Whether Judge Teh's active participation in the certiorari proceedings constituted a violation of judicial conduct and the Rules of Court.
  2. Whether Judge Teh's failure to act on the motion for inhibition in accordance with the prescribed procedure warranted administrative sanctions.

Arguments:

  • Complainant (Atty. Macalintal): Atty. Macalintal argued that Judge Teh's actions were inappropriate and demonstrated gross ignorance of the law. He contended that Judge Teh's participation in the certiorari proceedings was unnecessary and that his refusal to act on the motion for inhibition was a violation of judicial protocol.

  • Respondent (Judge Teh): Judge Teh defended his actions by stating that he filed comments and manifestations out of respect for the COMELEC's order. He claimed that his involvement was necessary to clarify the issues raised by Atty. Macalintal. Furthermore, he argued that the motion for inhibition lacked sufficient basis and sought to impose attorney's fees on Atty. Macalintal for compelling him to engage counsel.

Court's Decision and Legal Reasoning:

The Supreme Court found Judge Teh guilty of gross ignorance of the law and misconduct. The Court emphasized that judges must maintain a detached attitude in cases where their decisions are being challenged. It reiterated that a judge should not actively participate in proceedings related to their own decisions unless specifically directed by a higher court. The Court highlighted that Judge Teh's actions not only violated procedural rules but also undermined public confidence in the judiciary.

The Court noted that while Rule 140 of the Rules of Court typically requires complaints against judges to be sworn, it deemed it appropriate to dispense with this requirement in this case due to the nature of the allegations and Judge Teh's admissions. The Court invoked the doctrine of res ipsa loquitur, indicating that the judge's actions were so egregious that they spoke for themselves.

Ultimately, the Court dismissed Judge Teh from service, forfeiting all benefits and barring him from re-employment in any government position. The decision underscored the importance of judicial integrity, competence, and adherence to procedural norms.

Significant Legal Principles Established:

  1. Judges must maintain a detached and impartial stance in cases where their decisions are being contested.
  2. Active participation by a judge in proceedings related to their own rulings is inappropriate and can lead to administrative sanctions.
  3. The doctrine of res ipsa loquitur can be applied in cases of judicial misconduct where the actions of the judge are self-evident in their impropriety.