TARLAKENYO (April 16, 2025) – The Supreme Court (SC) has affirmed the validity of 1,237 orders and decisions issued by suspended Regional Trial Court (RTC) Judge Liberty Castañeda of Paniqui, Tarlac, despite her controversial dismissal in 2010 over administrative charges.
In a resolution dated Oct. 29, 2024, but made public only this week, the SC en banc ruled that retroactively nullifying Castañeda’s rulings would disrupt the judicial system, forcing the reopening of numerous cases and harming the rights of litigants.
Judge Castañeda was initially suspended on Jan. 12, 2010, following administrative charges, which included allegations of gross misconduct and inefficiency. Despite her suspension, she continued to preside over cases, issuing the more than 1,200 rulings before her eventual dismissal on Oct. 9, 2012.
The Supreme Court, in its latest ruling, noted that Castañeda believed she was entitled to resume her duties after a 90-day suspension, citing the Uniform Rules on Administrative Cases in the Civil Service, which state that an official should be automatically reinstated if no final decision is rendered within that period. However, her dismissal was later upheld due to the gravity of the charges against her.
Associate Justice Maria Filomena Singh, who penned the decision, emphasized that invalidating Castañeda’s judicial acts retroactively would create chaos in the legal system. The Court applied the de facto officer doctrine, which validates the acts of an official who assumed office under color of authority, even if their appointment or continuance was later deemed improper.
The SC also invoked the operative fact doctrine, which recognizes the legal effects of actions taken in good faith before a ruling’s nullification. The Court found no evidence that Castañeda acted in bad faith, as the public and litigants were unaware of her suspension, and she genuinely believed she had the authority to rule on cases.
The ruling came after civil registrars and litigants sought clarification on the validity of Castañeda’s decisions, particularly in annulment cases. The SC warned that overturning her rulings would destabilize the judiciary, forcing courts to revisit years-old cases and undermining public trust in legal finality.
While Castañeda’s dismissal underscored accountability for judicial misconduct, the Supreme Court stressed that the greater interest of justice required upholding her past decisions to prevent systemic disruption. The decision thus balances judicial integrity with the practical necessity of maintaining legal order.
