Case Digest (A.M. No. RTJ-00-1530)
Facts:
The case involves Dr. Edgardo Alday, Mercedes Favis, Marna Villafuerte, and Christopher Garcia as complainants against Judge Escolastico U. Cruz, Jr., of the Regional Trial Court, Makati City, Branch 58. The events leading to this case began with a traffic altercation on March 14, 2001, during which Judge Cruz allegedly threatened the complainants with a firearm. Following this incident, the Supreme Court of the Philippines found Judge Cruz guilty of conduct grossly prejudicial to the service and subsequently suspended him for one year, along with a fine of P50,000. The decision was promulgated on March 14, 2001, and Judge Cruz received a copy of the decision on March 22, 2001. Despite the suspension order, Judge Cruz continued to perform his judicial duties, which was reported to the Supreme Court by Executive Judge Leticia P. Morales in a letter dated August 1, 2001. The Supreme Court issued a resolution on September 18, 2001, voiding all orders and decisions made by Judge ...
Case Digest (A.M. No. RTJ-00-1530)
Facts:
- Initial Suspension Order: On March 14, 2001, the Supreme Court suspended Judge Escolastico U. Cruz, Jr., for one year and imposed a P50,000 fine for conduct grossly prejudicial to the service. This was due to a complaint filed by Dr. Edgardo Alday, Mercedes Favis, Marna Villafuerte, and Christopher Garcia, who accused him of threatening them with a gun during a traffic altercation.
- Failure to Comply with Suspension: Despite receiving the suspension order on March 22, 2001, Judge Cruz continued to perform his judicial duties. This was reported by Executive Judge Leticia P. Morales of the Regional Trial Court (RTC), Makati City, in a letter dated August 1, 2001.
- Voiding of Orders and Decisions: On September 18, 2001, the Supreme Court voided all orders, decisions, and issuances made by Judge Cruz during his suspension period (after March 22, 2001).
- Show Cause Order: The Court ordered Judge Cruz to explain why he should not be cited for contempt or penalized for disregarding the suspension order.
- Judge Cruz’s Explanation: In his September 26, 2001, explanation, Judge Cruz claimed he misunderstood the suspension order, believing it was not immediately executory. He argued that immediate compliance would have rendered the decision final and abandoned his office.
- OCA Investigation: The Office of the Court Administrator (OCA) recommended Judge Cruz’s dismissal for grave misconduct, citing his deliberate defiance of the Court’s suspension order.
Issue:
- Whether Judge Cruz’s continued performance of judicial duties during his suspension constitutes grave misconduct.
- Whether Judge Cruz’s explanation for his actions is valid and sufficient to justify his non-compliance with the suspension order.
- Whether the penalty of dismissal is appropriate for Judge Cruz’s actions.
Ruling:
The Supreme Court found Judge Escolastico U. Cruz, Jr., GUILTY of grave misconduct prejudicial to the administration of justice. He was ordered DISMISSED from the service, with forfeiture of all retirement benefits (except accrued leaves) and barred from reemployment in any government branch or instrumentality. The Court also declared all orders, decisions, and issuances made by Judge Cruz during his suspension period NULL and VOID.
Ratio:
- Immediate Effect of Suspension Orders: Administrative penalties, including suspension, are immediately executory upon receipt of the decision. Filing a motion for reconsideration does not stay the execution of the suspension order.
- Judges’ Duty to Comply with Court Orders: Judges are expected to have a thorough understanding of the law and jurisprudence. Ignorance or misapprehension of the law is not a valid defense, especially for a judge.
- Grave Misconduct: Judge Cruz’s deliberate refusal to comply with the suspension order constitutes grave misconduct, warranting the supreme penalty of dismissal. This is consistent with Civil Service Memorandum Circular No. 30, s. 1989, which imposes dismissal for grave misconduct even for a first offense.
- Preservation of Judicial Integrity: The Court emphasized that directives issued by the Supreme Court must be obeyed without delay to ensure the effective and efficient administration of justice. Judge Cruz’s defiance undermined the integrity of the judiciary.