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ANTONINO MONTICALBO v. JUDGE CRESCENTE F. MARAYA

FACTS:

Complainant Antonino Monticalbo filed a complaint against respondent Judge Crescente F. Maraya, Jr. of the Regional Trial Court, Branch 11, Calubian, Leyte, accusing him of gross ignorance of the law, gross incompetence, and grave abuse of authority through false representation. The complaint arose from a civil case for collection of a sum of money filed against Monticalbo and his wife by Fatima Credit Cooperative before the 6th Municipal Circuit Trial Court of Calubian-San Isidro, Leyte. The MCTC dismissed the case but did not rule on Monticalbo's counterclaim. Monticalbo filed a motion for reconsideration, which was denied. He then appealed the case to the RTC, where his motion for extension of time to file a memorandum on appeal was granted. However, the respondent judge dismissed the appeal for being filed out of time based on the Rules on Summary Procedure. Monticalbo accused the respondent judge of several errors and of accepting bribes from the plaintiff cooperative. Respondent judge denied the accusations and stated that the dismissal of the appeal was in accordance with the rules. The administrative complaint was referred to the Executive Justice of the Court of Appeals for investigation. The Investigating Justice recommended that the respondent judge be absolved of the charge of grave misconduct and bribery but be admonished and strictly warned for citing a non-existent case in his order. The Supreme Court agreed with the findings and stated that there must be proof of bad faith or corruption to merit disciplinary action against a judge.

ISSUES:

  1. Whether the respondent judge should be held liable for deliberately rendering an unjust judgment or order.

  2. Whether the respondent judge should be held liable for gross ignorance of the law.

  3. Whether the filing of an administrative case against a judge is an alternative, complementary, or supplementary to other judicial remedies provided by law.

RULING:

  1. The Court held that the complainant failed to substantiate his allegations of grave misconduct and bribery against the respondent judge. Mere assertions and conjectures cannot be given credence and charges based on mere suspicion and speculation cannot be upheld. The administrative complaint was dismissed for lack of merit.

  2. The Court ruled that the complainant's claim was indeed covered by the Rules on Summary Procedure. The complainant's argument that his claim exceeded the P10,000.00 limit set in the rule was mistaken. The rule was amended, and the ceiling was raised to P100,000.00. The complainant's criticism of the respondent judge's knowledge of the law was unfounded. Even if the respondent judge erred in issuing the questioned order, he cannot be held liable as long as he acted in good faith.

  3. The Court ruled that the filing of an administrative case against a judge is not an alternative, complementary, or supplementary to other judicial remedies provided by law. Disciplinary proceedings and criminal actions against judges are not a substitute for the available judicial remedies, whether ordinary or extraordinary. It is only after the exhaustion of these judicial remedies and a final judgment has been rendered that other measures, civil, administrative, or criminal, may be taken against the judge concerned.

PRINCIPLES:

  • Evident bad faith is required to hold a judge liable for deliberately rendering an unjust judgment or order.

  • The burden of proof rests on the complainant in administrative proceedings to substantiate their claims.

  • Charges based on mere suspicion and speculation cannot be given credence.

  • The Court will protect innocent court employees from groundless accusations or administrative charges.

  • Respondent judge can be held liable for gross ignorance of the law if the error is so gross and patent as to produce an inference of bad faith.

  • Acts complained of must not only be contrary to existing law and jurisprudence but also motivated by bad faith, fraud, dishonesty, and corruption.

  • A judge's erroneous actions, as long as they were done in good faith, will not subject the judge to disciplinary action.

  • Criticizing a judge with insulting language and unfair criticism violates the lawyer's duty to accord due respect to the courts.

  • Filing an administrative case against a judge is not an alternative to the other judicial remedies available.

  • Disciplinary proceedings and criminal actions against judges are not alternative, complementary, or supplementary remedies to judicial remedies. These actions are not substitutes for the available judicial remedies, whether ordinary or extraordinary.

  • A judge must observe propriety, discreetness, and due care in the performance of official duties. Judges should strive to live up to the strict standards of competence, integrity, and diligence in public service necessary for one in their position.

  • A judge should be the embodiment of competence, integrity, and independence. The Code of Judicial Conduct demands that judges be faithful to the law and maintain professional competence.

  • Disciplinary action may be imposed on a judge for citing a non-existent case. While a judge may not be disciplined for an error of judgment without proof of deliberate intent to cause injustice, judges are required to observe propriety, discreetness, and due care in the performance of their official duties.