Title
Baldoza vs. Dimaano
Case
A.M. No. 1120-MJ
Decision Date
May 5, 1976
Municipal Secretary accused Judge Dimaano of abuse for restricting access to court records; SC ruled conditions imposed were reasonable, dismissing the case.

Case Digest (A.M. No. 1120-MJ)
Expanded Legal Reasoning Model

Facts:

  • Parties
    • Complainant: Dominador C. Baldoza, Municipal Secretary of Taal, Batangas.
    • Respondent: Hon. Judge Rodolfo B. Dimaano, Municipal Judge of Taal.
  • Nature and Origin of the Complaint
    • On September 9, 1975, the complainant filed a verified letter-complaint charging the respondent with abuse of authority for allegedly refusing municipal employees permission to examine the Municipal Court’s criminal docket records to prepare a report on peace and order.
    • Respondent’s answer denied any intent to refuse access, acknowledged that court records are public documents subject to reasonable regulations, and explained his concern over partisan political abuse and the need for Supreme Court–issued guidelines.
  • Proceedings Below
    • The case was referred to Judge Francisco Mat. Riodique for investigation and report.
    • At the preliminary hearing (October 16, 1975), Mayor Corazon A. Caniza moved to dismiss for the sake of municipal harmony; the motion was denied, and the complainant presented only documentary communications.
    • The Investigating Judge found no abuse of authority, noting that respondent allowed inspection under conditions, and recommended exoneration.

Issues:

  • Whether Judge Dimaano abused his authority by refusing or unduly restricting access to the criminal docket records.
  • Whether the rules and conditions imposed by the respondent on inspection were unreasonable or prohibitive.
  • Whether, under existing law and policy, the respondent was justified in seeking Supreme Court guidelines before granting unfettered access.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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