Supreme Court Dismisses Baseless Complaint Against CA Justice and Lawyer

The Supreme Court has dismissed administrative complaints against Associate Justice Jane Aurora C. Lantion of the Court of Appeals and Atty. Dorothy S. Cajayon, who were accused of selling favorable decisions. The case underscores the importance of verified complaints and substantial evidence in disciplinary proceedings against members of the judiciary and the bar.

Background of the Case

In September 2016, Rosa Abdulharan filed a letter with the Office of the President alleging that Atty. Cajayon was telling litigants with pending cases before the Court of Appeals in Cagayan de Oro City to prepare money because Justice Lantion was giving a "favorable decision if the price is right." A similar letter from Rafael Dimaano was later filed with the Department of Justice, requesting an investigation into an alleged syndicate selling favorable decisions.

Both letters were referred to the Supreme Court through the Office of the Court Administrator. The complaints were consolidated, and Justice Lantion and Atty. Cajayon were required to comment.

The Respondents' Defense

Atty. Cajayon denied knowing the complainants and stated that in her 29 years of legal practice, she had never dealt with them. She asserted that she had no appealed cases before the division where Justice Lantion sat and had never proposed to bribe any public officer or magistrate. While she acknowledged that Justice Lantion was her underclasswoman in law school, she maintained they had no professional or personal association.

Justice Lantion similarly denied the charges, calling them false and malicious. She noted that she was assigned to the Court of Appeals in Cagayan de Oro for only two and a half years, from February 2007 to August 2009, making it highly improbable for her to have established connections for such a scheme. She also pointed out that the complaints were filed nearly eight years after her transfer to Manila and that she had no personal knowledge of Atty. Cajayon's identity.

The Court's Ruling

The Supreme Court dismissed the complaints for lack of merit. The Court cited Section 1, Rule 140 of the Rules of Court, which provides that proceedings against justices of the Court of Appeals may be instituted motu proprio by the Supreme Court, upon a verified complaint supported by affidavits of persons with personal knowledge, or upon an anonymous complaint supported by public records of indubitable integrity.

Similarly, Section 1, Rule 139-B of the Rules of Court requires that complaints against lawyers be verified and supported by affidavits or documents substantiating the facts alleged.

The Court noted that the handwritten letter-complaints were not only unverified but also unsupported by any affidavits or documents. The allegations were couched in general terms and contained no specific acts showing that Justice Lantion and Atty. Cajayon were involved in selling favorable decisions. The Court also observed that the complaints were filed seven years after Justice Lantion had been transferred to Manila.

In administrative proceedings, the quantum of proof required is substantial evidence—that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion. The burden falls on the complainant to substantiate the charges. Mere allegations, conjectures, and suppositions are insufficient.

Citing Diomampo v. Judge Alpajora (483 Phil. 560 [2004]), the Court stressed that administrative complaints against judges must be examined with a discriminating eye, as they carry highly penal consequences. The Court must be quick in dismissing complaints that serve no purpose other than to harass members of the judiciary.

Practical Takeaways

• Administrative complaints against judges and lawyers must be verified and supported by affidavits or documents to be given due course.
• Mere allegations, conjectures, and suppositions are not enough to establish liability in disciplinary proceedings.
• Complainants bear the burden of proving their charges with substantial evidence.
• The Supreme Court will protect judges and lawyers from baseless administrative charges that disrupt the orderly administration of justice.
• Unverified complaints filed long after the alleged acts may be viewed with suspicion, especially when they lack specific factual allegations.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.