CORPUS B. ALZATE vs. HON. RAPHIEL F. ALZATE
- G.R. Number: A.M. No. RTJ-25-099
- Promulgated: 2025-08-05
Doctrine
## Facts of the Case Complainant Judge Corpus Alzate filed a complaint against respondent Judge Raphiel F. Alzate, alleging misconduct and dishonesty related to annulment cases. Complainant claimed that respondent's court, Branch 58, RTC, Bucay, Abra, was known as the "Annulment Capital of the North" due to respondent allegedly disregarding residency requirements. It was further alleged that respondent and his wife, Atty. Maria Saniata Liwliwa Gonzales-Alzate, engaged in a "conjugal syndicate" offering "package deals" for quick annulments, with Atty. Gonzales-Alzate initially dealing with parties and later assigning cases to lawyers who often did not participate in the proceedings. Complainant cited two specific cases, *Villanueva v. Villanueva* and *Bermudez v. Bermudez*, where respondent allegedly decided favorably despite irregularities. In *Villanueva*, Atty. Gonzales-Alzate was the initial counsel, and despite her withdrawal after respondent became acting judge, minutes purportedly showed her continued appearance. In *Bermudez*, it was alleged that the assigned lawyer only signed the petition as an accommodation and was not notified of hearings. Respondent denied the accusations, stating that his wife legitimately withdrew from *Villanueva* and that the parties in both cases were bonafide residents of Bucay, Abra. The Office of the Court Administrator (OCA) recommended referral to the Court of Appeals (CA) for investigation. The Investigating Justice found insufficient evidence for gross misconduct or dishonesty but recommended a judicial audit. The Judicial Integrity Board (JIB) and its Office of the Executive Director (OED) affirmed the insufficiency of evidence for corruption but found respondent liable for not inhibiting from *Villanueva* due to his wife's prior involvement. ## Issues 1. Whether respondent Judge Raphiel F. Alzate is guilty of gross misconduct and dishonesty. 2. Whether respondent Judge Raphiel F. Alzate is guilty of gross ignorance of the law for failing to inhibit from *Villanueva v. Villanueva*. ## Decision / Rationale **Issue 1:** The Court concluded that **complainant failed to prove by substantial evidence** that respondent is guilty of gross misconduct and dishonesty. The allegations that respondent and his wife engaged in a "modus of negotiating 'package deals'" for annulment cases were unsubstantiated. The claim that respondent decided cases for non-residents was adequately rebutted by affidavits and certifications. The alleged continued appearance of Atty. Gonzales-Alzate in *Villanueva* after her withdrawal was explained as an inadvertence by a court staff member. While there were conflicting affidavits from Atty. Byrone B. Alzate regarding his participation in *Bermudez*, the Court found no other competent evidence to support the claims of corruption or an "accommodation lawyer" scheme linked to respondent. **Issue 2:** The Court found **Judge Raphiel F. Alzate guilty of gross ignorance of the law or procedure** for his failure to inhibit from *Villanueva v. Villanueva*. The Court emphasized that **Rule 137, Section 1 of the Rules of Court**, and **Canon III, Section 5(f) and (g)**, and **Canon IV, Section 4 of the New Code of Judicial Conduct** mandate compulsory disqualification when a judge's spouse served as counsel in a case, especially when the spouse actively participated prior to the judge assuming the bench or its duties regarding the case. Respondent did not deny that his wife initially filed the petition and presented evidence in *Villanueva*. His defense that his wife withdrew her appearance before he "tried" the case was rejected because her prior active participation created a perception of bias or partiality. The Court cited **Paderanga v. Judge Paderanga** which established that disobedience to rules on compulsory self-disqualification constitutes gross ignorance of the law. Given that this was respondent's second offense for violating the rule on compulsory disqualification…
Keywords
Rule 137 Section 1 Rules of Court, Canon III Section 5 New Code of Judicial Conduct, Canon IV Section 4 New Code of Judicial Conduct, Rule 140 Rules of Court, Compulsory Disqualification, Appearing to be Impartial, Judicial Misconduct, Gross Ignorance of the Law, Annulment of Marriage Cases, Substantial Evidence, Perception of Bias, Affinity, Consanguinity, Voluntary Inhibition, Modus Operandi, Pre-trial, Collusion Reports, Gross Neglect of Duty, Judge Found Guilty, Fine Imposed