Facts:

In the administrative matter numbered 1381-MJ, Jesus Banawa filed a complaint against Municipal Judge Gregorio B. de Jesus of Bacolor, Pampanga, accusing him of several misconducts, including gross negligence in document custody, grave abuse of power, ignorance of law, obstruction of justice, and acts unbecoming of a judge. The complaint stemmed from an incident on July 19, 1976, when Banawa attempted to present a bail bond related to criminal cases against him. The judge refused to approve the bond due to the size of the ID pictures attached, which were 1x1" instead of the required 2x2". Subsequent efforts by Banawa to file a criminal complaint against two individuals were obstructed by Judge de Jesus, who reportedly tore the complaint documents in a fit of temper, citing legal inadequacies.

In Administrative Matter No. 1633-MJ, Ricardo Nuqui and others were involved in a case of illegal cockfighting where Judge de Jesus lent Nuqui the gaffs taken as evidence, expecti

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Facts:

Administrative Matter No. 1381-MJ (Jesus Banawa et al. vs. Judge Gregorio B. de Jesus)

• Complainant Jesus Banawa charged the respondent judge with multiple offenses:
• Gross negligence and infidelity in the custody of public documents.
• Grave abuse of power and discretion.
• Ignorance of the law.
• Obstruction of justice.
• Oppression and acts unbecoming of a judge.
• The incident arose when Banawa sought approval of his bail bond for criminal cases (Cases Nos. 1422 and 1423).
• The respondent questioned the size of the ID picture attached to the bail bond (1" x 1" instead of the prescribed 2" x 2").
• Despite Banawa’s request to remedy the deficiency by having a new picture taken downtown, the respondent refused and ordered his immediate detention.
• During proceedings in the judge’s office:
• The complainant presented various documents including a verified complaint letter, affidavits, a medical certificate, and supporting exhibits.
• The respondent, visibly impatient and temperamental, altered the complaint record by tearing and criss-crossing documents, actions that Banawa alleged showed gross negligence and an abuse of judicial discretion.
• Subsequent events included:
• Banawa’s repeated attempts to retrieve the pertinent documents from the judge.
• A delay caused by the late retrieval of documents by the Chief of Police.
• An independent investigation revealing multiple failings by the respondent, including failure to docket the case, record proceedings, and conduct a thorough preliminary examination.

Administrative Matter No. 1633-MJ (Ricardo Nuqui vs. Judge Gregorio B. de Jesus)

• Background in Criminal Case No. 1394:
• Nuqui, along with others, was charged with illegal cockfighting.
• Seven “gaffs” (tari) were seized as evidence; Nuqui pleaded guilty and was fined.
• Subsequent to the case:
• The respondent judge retained the seven gaffs rather than ordering their forfeiture to the State.
• Nuqui, facing financial hardship, requested the return of the gaffs for his livelihood.
• Developments:
• Out of compassion, the judge lent the gaffs to Nuqui under a receipt promising their return upon order.
• When Nuqui later defaulted by not returning the gaffs, the respondent ordered his detention for nearly twelve hours (from approximately 9:00 A.M. to past 8:00 P.M. on April 11, 1977).
• Nuqui subsequently filed complaints alleging arbitrary detention, illegal issuance of interlocutory orders, and violations under the Anti-Graft Law (R.A. No. 3019).

Administrative Matter No. 1645-MJ (Ruben Lacsa and Castor Carbungco vs. Judge Gregorio B. de Jesus)

• Complainants Lacsa and Carbungco sought to file two criminal complaints:
• One for Qualified Theft against identified persons.
• And another for Resistance and Disobedience to a Person in Authority.
• The respondent judge refused to docket these complaints:
• His basis was the non-compliance with the required verification (i.e., the complaints were not sworn under oath as mandated by law).
• Additional allegations by the complainants:
• The judge allegedly defended the accused by producing an affidavit indicating that some offended parties had “forgiven” the accused.
• The complainants perceived this as a refusal to perform his judicial duty and conduct prejudicial to the interests of the service.
• In his response:
• The judge contended that his refusal was due solely to the absence of the mandatory oath, insisting that proper procedure required verification before docketing any criminal complaint.

Administrative Matter No. 2042-MJ (Edilberto Mercado vs. Judge Gregorio B. de Jesus)

• Complainant Edilberto Mercado presented a complaint involving:
• An incident on July 20, 1978, when he sought to file a complaint based on a sworn statement regarding grave threats against a person named Fred Smith.
• The respondent judge’s handling of the matter:
• He returned the documents to Mercado with a remark that no case existed.
• He suggested that the complaint be forwarded to the Fiscal’s Office.
• He further opined that the testimony of a peace officer would be more credible than that of Mercado’s relative (a first cousin), thus undermining the basis of the complaint.
• Investigation findings:
• The complaint was eventually dismissed on recommendation by the investigating judge due to the apparent lack of interest by Mercado to push the matter further.

Issue:

For Administrative Matter No. 1381-MJ:

• Whether the respondent judge’s refusal to accept the bail bond based on a technical picture size defect and the subsequent actions (tearing and disregarding properly sworn documents) constituted gross negligence and abuse of judicial discretion.
• Whether such actions amounted to acts unbecoming of a judge and a violation of the proper administrative procedures in handling criminal documents.

For Administrative Matter No. 1633-MJ:

• Whether the retention and lending of the gaffs, coupled with the prolonged detention of Nuqui for failing to return them, were justified under the court’s discretion.
• Whether the detention imposed constituted arbitrary or unjust exercise of judicial power, especially in light of the procedural requirements for enforcing court orders.

For Administrative Matter No. 1645-MJ:

• Whether the respondent judge’s refusal to docket criminal complaints not verified under oath deviated from proper judicial procedure.
• Whether the additional allegation of “defending the accused” by alluding to prior forgiveness by offended parties had any merit within the framework of judicial discretion.

For Administrative Matter No. 2042-MJ:

• Whether the respondent judge’s dismissal of Mercado’s complaint—by redirecting him to the Fiscal’s Office and downplaying his evidence—amounted to ignorance of the law or conduct prejudicial to the best interest of the judiciary.
• Whether the judge provided Mercado with the adequate opportunity to pursue his complaint following due process requirements in cases of indirect contempt.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)