Case Digest (A.M. No. 852-MJ)
Facts:
The case involves Felisberto Alegre as the complainant and Municipal Judge Rhodie A. Nidea of Sipocot, Camarines Sur as the respondent. The complaint was filed on May 30, 1975, alleging partiality and favoritism by Judge Nidea. Alegre claimed that the judge's actions were biased against him, which he believed affected the outcome of his case. In response to the complaint, Judge Nidea denied any allegations of partiality or favoritism. The Department of Justice, which had administrative oversight over inferior courts at the time, referred the matter to Executive Judge Ulpiano Sarmiento of the Court of First Instance of Camarines Sur for an inquiry into the allegations. During the investigation scheduled for November 27, 1969, both Alegre and his lawyer failed to appear, while Judge Nidea was present. The records indicated that Alegre had filed a motion to dismiss the complaint, stating that the issue arose from a misunderstanding that had since been resolved. The District...
Case Digest (A.M. No. 852-MJ)
Facts:
- Complaint Filed: Felisberto Alegre filed an administrative complaint against Municipal Judge Rhodie A. Nidea of Sipocot, Camarines Sur, alleging partiality and favoritism.
- Respondent's Defense: Judge Nidea denied the allegations, stating that his conduct did not manifest partiality or favoritism.
- Investigation by Executive Judge: The Department of Justice referred the matter to Executive Judge Ulpiano Sarmiento of the Court of First Instance of Camarines Sur to investigate the allegations of bias, leniency, undue severity, and strictness.
- Failure to Appear: During the scheduled investigation on November 27, 1969, complainant Alegre and his lawyer failed to appear. Instead, they filed a motion to dismiss the case, attaching an affidavit (Annex A) stating that the complaint arose from a misunderstanding that had already been resolved.
- Postponements: The case had been postponed twice at the request of the complainant.
- Recommendation for Dismissal: Judge Sarmiento recommended dismissing the case due to the complainant's lack of cooperation and the filing of the motion to dismiss.
- Transfer to Supreme Court: The case was transferred to the Supreme Court under the new Constitution, which granted the Court supervisory authority over inferior courts.
- Judicial Consultant's Memorandum: The Office of the Judicial Consultant reviewed the case and recommended dismissal, citing the complainant's failure to substantiate the charges and his affidavit of desistance.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Lack of Substantiation: The complainant failed to appear during the investigation to substantiate his allegations, which is crucial for the success of an administrative complaint.
- Affidavit of Desistance: The complainant filed an affidavit stating that the complaint was based on a misunderstanding that had already been resolved, effectively withdrawing the charges.
- Judicial Discretion: The Court upheld the recommendation of the Judicial Consultant and the investigating judge, emphasizing that the dismissal was proper given the complainant's lack of cooperation and desistance.
- Supervisory Authority: The Supreme Court exercised its constitutional authority to supervise inferior courts, ensuring that administrative complaints are resolved fairly and justly.