Case Digest (A.M. No. RTJ-16-2443)
Facts:
This case involves an administrative complaint filed by Armando M. Balanay against Judge Juliana Adalim-White of the Regional Trial Court, Branch 5, Eastern Samar. The complaint was lodged on September 20, 2010, with the Office of the Court Administrator (OCA), alleging gross ignorance of the law and serious misconduct. The complainant accused the respondent of allowing Isidoro N. Adamas, Jr., who was charged with murder in Criminal Case No. 10-07, to take six furloughs despite the non-bailable nature of the offense. The complainant contended that the respondent granted these furloughs without requiring the prosecution to comment or providing an opportunity for the prosecution to be heard. Furthermore, the complainant claimed that the respondent improperly dismissed Criminal Case No. 10-07, asserting that the prosecution had no witnesses when, in fact, the records indicated otherwise. The prosecution's witnesses were absent due to lack of notification, and the complainant...
Case Digest (A.M. No. RTJ-16-2443)
Facts:
Complaint Filed Against Respondent Judge:
- Complainant Armando M. Balanay filed an administrative complaint against Judge Juliana Adalim-White for gross ignorance of the law and serious misconduct.
- The complaint stemmed from the judge's handling of Criminal Case No. 10-07, where the accused, Isidoro N. Adamas, Jr., was charged with murder, a non-bailable offense.
Allegations of Gross Ignorance of the Law:
- Respondent judge granted Adamas six furloughs without requiring the prosecution to comment or giving them an opportunity to be heard.
- The motions for furlough did not comply with the 3-day notice rule and were not set for hearing.
Allegations of Serious Misconduct:
- Respondent judge dismissed Criminal Case No. 10-07 on the ground that the prosecution had no witnesses to present, despite records showing that witnesses were available but not notified.
- Complainant alleged that the judge falsified the July 22, 2010 transcript of stenographic notes (TSN) by instructing her stenographer to delete a reservation to present additional witnesses and insert fabricated statements.
Respondent’s Defense:
- Respondent admitted instructing her stenographer to correct the TSN to make it more coherent and accurate, claiming the changes were based on her notes and verified from taped recordings.
- She justified granting furloughs based on affidavits of desistance and Adamas’ voluntary surrender, arguing he was not a flight risk.
Investigation and Recommendations:
- The case was referred to Justice Maria Elisa Sempio Diy, who found respondent guilty of gross ignorance of the law for granting furloughs without proper procedure but absolved her of serious misconduct due to lack of proof of corruption.
- The Office of the Court Administrator (OCA) agreed with Justice Diy’s findings but also found respondent guilty of serious misconduct for altering the TSN.
Respondent’s Prior Administrative Cases:
- Respondent had previously been found administratively liable for impropriety and conduct unbecoming of a judge in two prior cases.
Issue:
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Ruling:
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Ratio:
Gross Ignorance of the Law:
- Judges are expected to be conversant with basic legal principles and procedural rules. Granting furloughs without a hearing or proper notice violates fundamental rules, especially in non-bailable offenses like murder.
Gross Misconduct:
- Altering court records, such as the TSN, to include fabricated statements constitutes a serious breach of judicial ethics and undermines the integrity of the judicial process.
Penalty:
- The Court imposed a harsher penalty due to respondent’s repeated administrative violations and failure to heed prior warnings. This serves as a deterrent against future misconduct.