Facts:

The case in question involves Olivia L. Bambo-Jorin as the complainant against Judge Arnulfo A. Singson, who served in the Municipal Trial Court of Tanay, Rizal. The complaint, filed on April 26, 1992, alleges that Judge Singson was negligent and displayed incompetence and ignorance of the law whilst handling Criminal Cases Nos. 5714 and 5715, which involved the prosecution of Teresita Sabiniano for Slight Physical Injuries and Oral Defamation, respectively. The cases had initially been overseen by Judges Amado Calderon and Jaime Manaois before being inherited by Judge Singson in 1989. Several irregularities were pointed out by the complainant:

1. Judge Singson issued a Notice of Promulgation of Judgment on April 1, 1992, despite the judgment itself being dated April 2, 1992, leading to confusion regarding the timelines.
2. In sentencing, he imposed the penalty of arresto menor without specifying the period in the case of Slight Physical Injuries and a fine of P200.00 in the Oral De

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Facts:

Background of the Case

• Olivia L. Bambo-Jorin, the complainant, filed a sworn letter-complaint on April 26, 1992, against Judge Arnulfo A. Singson.
• The complaint was directed against alleged negligence, incompetence, and ignorance of the law in criminal cases.
• The cases in question were Criminal Cases Nos. 5714 and 5715, covering crimes of Slight Physical Injuries and Oral Defamation, respectively, under the title “People of the Philippines vs. Teresita Sabiniano.”

Procedural History and Handling of the Cases

• The cases were initially filed and tried by two former Municipal Judges, Judge Amado Calderon and Judge Jaime Manaois, at the Municipal Trial Court of Tanay, Rizal.
• Judge Arnulfo A. Singson inherited these cases in 1989 and subsequently handled them.
• The record reveals multiple alleged irregularities and procedural errors attributed to Judge Singson’s management of the cases.

Alleged Irregularities and Errors Noted by the Complainant

• Promulgation Notice Error
• A Notice of Promulgation of Judgment was issued on April 1, 1992, ordering an appearance on April 6, 1992, despite the decision being dated April 2, 1992.
• Improper Imposition of Penalties in the Slight Physical Injuries Case
• The accused was sentenced to suffer arresto menor without specifying the duration.
• In conjunction, a fine of ₱200.00 was also imposed, an action contrary to the provision that mandates either imprisonment or a fine, but not both.
• Unauthorized and Excessive Adjournment of Trial Proceedings
• The trial was reset on several occasions, exceeding the legal period (more than one month at a time and cumulatively more than three months) without the necessary written authority from the Chief Justice.
• Issuance of a Probation Order Without Proper Notification
• An order was issued on April 12, 1992, directing the accused to report to the Probation Officer within 72 hours.
• The trial prosecutor was not given an opportunity to comment on the issuance of this order.

Respondent Judge Singson’s Defense and Explanation

• Clerical Error Justification
• The error in the promulgation notice date was attributed to clerical mistakes made by stenographers.
• Consent of Counsel on Adjournments
• Though he admitted to adjournments longer than permitted, the judge claimed these were done with the consent of both counsels, who even selected their available dates.
• Admittance of Improper Imposition in the Slight Physical Injuries Case
• Judge Singson acknowledged the error in not specifying the period for arresto menor, describing it as an oversight due to haste amid a heavy volume of cases.
• Justification Regarding the Probation Order
• He argued that notifying the trial prosecutor was not required, citing Presidential Decree No. 1990 amending Section 4 of PD No. 968.

Evaluation and Recommendation by the RTC

• The case was referred to RTC Vice-Executive Judge Alejandro A. Marquez for evaluation, report, and recommendation.
• Judge Marquez recommended that Judge Singson be suspended from office for one (1) month without pay.

Court’s Findings and Final Disposition

• The reviewing court found no evidence of bad faith or intentional misconduct that would warrant a full one-month suspension.
• It was adjudged that, at most, Judge Singson was negligent in the improper imposition of the penalty in the Slight Physical Injuries case.
• The court highlighted that Article 266, paragraphs (2) and (3) of the Revised Penal Code provide for either arresto menor or a fine, but not both concurrently.
• In the Oral Defamation case, the imposition of a ₱200.00 fine was within the discretionary power of the trial court, as provided by Article 358 of the Revised Penal Code.

Issue:

Promulgation Notice

• Whether the error concerning the notice of promulgation (issued on April 1 for a decision dated April 2) constitutes a mere clerical mistake or a substantive violation of judicial procedure.

Imposition of Combined Penalties in the Slight Physical Injuries Case

• Whether imposing both arresto menor without a specified duration and a fine of ₱200.00 contravenes the provisions of Article 266, which stipulate that the penalty should be either imprisonment or a fine, but not both.

Excessive and Unauthorized Adjournment of Trial Proceedings

• Whether resetting the trial beyond the permissible adjournment periods without written authority constitutes a breach of judicial procedural rules.

Issuance of the Probation Order

• Whether the order directing the accused to report to the probation office without giving the trial prosecutor an opportunity to comment violates procedural due process, notwithstanding the reference to Presidential Decree No. 1990.

Judicial Discretion in the Imposition of Fines for Oral Defamation

• Whether the discretion exercised in imposing a ₱200.00 fine in the Oral Defamation case aligns with the statutory limits set forth in Article 358 of the Revised Penal Code, irrespective of the accused’s financial capacity.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)