Title
Albos vs. Alaba
Case
A.M. No. MTJ-91-517
Decision Date
Mar 11, 1994
Judge Alaba reprimanded for improper handling of a defamation case, failing to act on a motion for inhibition, and displaying dismissive conduct, undermining judicial impartiality and diligence.
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Case Digest (A.M. No. MTJ-91-517)

Facts:

  1. Filing of the Complaint: On 27 August 1990, Nimfa Albos filed a complaint for grave oral defamation against Rebecca Songalia with the Municipal Trial Court (MTC) of Tanauan, Leyte.
  2. Status Inquiry: In October 1990, Albos and her mother inquired about the status of the case and were informed by the Clerk of Court that the complaint was "not yet signed" by Judge Eugenio Alaba.
  3. Judge's Reaction: When they approached Judge Alaba, he reportedly threw the complaint on the table, stating, "Here they are; I am returning them to you anyway, they are useless. You will lose in your case."
  4. Re-filing of the Case: Albos hired a lawyer, and the complaint was re-filed with the Office of the Provincial Prosecutor. An information was subsequently filed with the MTC (Criminal Case No. 4486).
  5. Motion for Inhibition: On 14 January 1991, Albos filed a motion for Judge Alaba to inhibit himself from the case. The judge refused to act on the motion and allegedly challenged Albos' counsel to a fight.
  6. Dismissal of the Case: The case was dismissed on 14 February 1991 after Albos and her counsel failed to appear in court.

Issue:

  1. Whether Judge Eugenio Alaba committed grave misconduct, conduct unbecoming of a judge, oppression, and gross inefficiency in handling the case.
  2. Whether Judge Alaba's failure to act on the motion for inhibition and his subsequent dismissal of the case were justified.
  3. Whether Judge Alaba's conduct during the proceedings was appropriate and in line with judicial ethics.

Ruling:

The Supreme Court found that Judge Eugenio Alaba failed to act with the required prudence and diligence in handling the case. While there was no evidence of grave misconduct or oppression, his failure to act on the motion for inhibition and his dismissive attitude toward the complainant's concerns were improper. The Court reprimanded Judge Alaba and admonished him to exercise greater diligence in his official duties, warning that future similar offenses would be dealt with more severely.

Ratio:

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