RE: ANONYMOUS COMPLAINT AGAINST PRESIDING JUDGE ANALIE C.
ALDEA-AROCENA
A.M. No. MTJ-17-1889, September 3, 2019
FACTS:
The Office of the Court Administrator ordered Executive Judge Cynthia-Martinez Florendo of
the RTC of San Jose, Nueva Ecija to conduct an investigation and submit a report regarding the
accusations against Judge Analie Aldea-Arrocena.
One of the complaints against respondent stemmed from the civil cases involving a
cooperative, which her husband is a member of the directors. Respondent, allegedly,
mistreated the defendants in the case and the cooperative failed to pay the legal and filing fees.
In the said case, respondent’s husband, Ferdinand Arocena, filed two civil actions for collection
of sum of money against Teresita Palma and Rowena Anciete.
In the civil cases, to which respondent’s husband was involved, the penalty of 30% per annum
was not indicated in the promissory notes. However, upon the examination of the Court, it was
found that there is a penalty of 2.5% per month or 30% per annum in the promissory note.
Respondent Judge approved the compromise agreements even if the interest and penalty rates
provided were against law and public policy for being iniquitous and unconscionable.
Respondent Judge should have disapproved the said interest rates.
In her affidavit, Palma, one of the defendant’s in the civil case, admitted borrowing the amount
of P44,735.35 from Self-Reliant Cooperative. She alleged that respondent judge had talked to
her regarding the settlement of the amount on installment basis. Palma insists that there was
no compromise agreement not she agreed to pay the sum of P97,000.
Meanwhile, Anciete admitted that she borrowed P46,395.60 from Self-Reliant Cooperative.
Similar to Palma’s case, she did not sign any compromise agreement. She was surprised that
the principal amount in the decision had increased to P127,609.00. She mentioned that she
entered into a verbal agreement with respondent judge, wherein she promised to pay the
remaining balance during harvest time. She also disclosed that she did not receive a copy of the
court’s decision.
The OCA ruled that the records show that the Motions for Judgment Based on the Compromise
Agreement for the cases involving Palma and Anciete were signed by said defendants and were
in order.
ISSUE:
Whether or not respondent judge’s conduct constituted as gross ingnorance of the law and
abuse of authority?
RULING:
YES. The Court is led to the conclusion that respondent judge approved the unconscionable
compromise agreements to the favor of the cooperative, to which her husband is a member of
the board of directors. There is no other way to describe her conduct as gross ignorance of the
law and abuse of authority.
The Supreme Court found that the Compromise Agreements approved by respondent Judge
were contrary to law, morals, public policy and interest. In the report of Judge Florendo
(Executive Judge), she observed the compromise agreements approved by respondent judge
reflect iniquitous and unconscionable interest and penalties.
In the case of Sps. Castro v. Tan, it is mentioned that excessive interest rates are against law
and morals, even if agreed upon by the parties. In the present case, respondent judge failed to
apply the established jurisprudence on the imposition of interest on loan obligations. The loan
documents presented to her provided interest rates which are excessive and unreasonable. Her
omission to apply the correct rule constitutes gross ignorance of the law.
As a Judge, respondent is required to know Judge Arocena is required to be knowledgeable
about the rules and jurisprudence on interest rates because it is the duty of a judge to be
abreast with legal developments.
