Case Digest (A.M. No. MTJ-97-1132, MTJ-97-1133)
Facts:
In the case of Mario Cacayoren vs. Judge Hilarion A. Suller (A.M. No. MTJ-97-1132) and Teodoro B. Cacayoren vs. Judge Hilarion A. Suller (A.M. No. MTJ-97-1133), the complainants, Mario and Teodoro Cacayoren, filed administrative complaints against Judge Hilarion A. Suller of the 7th Municipal Circuit Trial Court (MCTC) in Asingan-San Manuel, Pangasinan. The complaints were lodged on the grounds of ignorance of the law, dishonesty, oppression, and violation of the Anti-Graft and Corrupt Practices Act.
The events leading to the complaints began on March 19, 1994, when Mario Cacayoren filed a complaint for frustrated murder against Atty. Felix Tacadena with the Office of the Provincial Prosecutor of Nueva Ecija. This complaint was dismissed on the basis of insufficient evidence. Subsequently, on November 10, 1994, Mario re-filed the case in the 2nd MCTC, General Natividad-Llanera, Nueva Ecija, where it was assigned Criminal Case No. 2238-L. While this case was still pendi...
Case Digest (A.M. No. MTJ-97-1132, MTJ-97-1133)
Facts:
Administrative Matter No. MTJ-97-1132 (Mario Cacayoren vs. Judge Hilarion A. Suller)
- Criminal Complaint for Frustrated Murder: On March 19, 1994, Mario Cacayoren filed a complaint for Frustrated Murder against Atty. Felix Tacadena before the Office of the Provincial Prosecutor of Nueva Ecija. The case was dismissed due to insufficient evidence to establish probable cause.
- Refiling of the Criminal Case: On November 10, 1994, Mario re-filed the case before the 2nd MCTC, General Natividad-Llanera, Nueva Ecija, where it was docketed as Criminal Case No. 2238-L. The case was still pending at the time of the administrative complaint.
- Civil Case for Damages: While the criminal case was pending, Judge Suller entertained a civil case for damages based on malicious prosecution (Civil Case No. SM-647) filed by Felix Tacadena against Mario Cacayoren. Judge Suller rendered a decision on December 15, 1995, in favor of Tacadena.
- Allegations: Mario alleged that Judge Suller should not have entertained the civil case since the criminal case had not yet been finally terminated with an acquittal. He also claimed that Judge Suller and Tacadena were close relatives, creating a conflict of interest.
Administrative Matter No. MTJ-97-1133 (Teodoro Cacayoren vs. Judge Hilarion A. Suller)
- Criminal Complaint for Theft of Large Cattle: On May 25, 1994, Teodoro Cacayoren filed a criminal case for Theft of Large Cattle against Victoria Mangilin, Donato Bustamante, Marfel Tacadena, and Jayson Cacayoren. The case was dismissed by the Provincial Prosecutor for lack of probable cause.
- Refiling of the Criminal Case: In November 1994, Teodoro re-filed the case before the 2nd MCTC, General Natividad-Llanera, Nueva Ecija, where it was docketed as Criminal Case No. 223-N. The case was still pending at the time of the administrative complaint.
- Civil Case for Damages: Judge Suller entertained a civil case for damages based on malicious prosecution (Civil Case No. SM-648) filed by Marfel Tacadena and Jayson Cacayoren against Teodoro. Judge Suller rendered a decision in favor of the plaintiffs.
- Allegations: Teodoro alleged that Judge Suller should not have entertained the civil case since the criminal case had not yet been finally terminated. He also accused Judge Suller of dishonesty and ignorance of the law for citing the superseded case of Ventura vs. Bernabe instead of Ponce vs. Legazpi. Teodoro further claimed that Judge Suller was a close relative of Marfel Tacadena, creating a conflict of interest.
Procedural History
- Both complainants filed Notices of Appeal from Judge Suller's decisions, but the appeals were denied for being filed beyond the reglementary period.
- The cases were consolidated and referred to Executive Judge Joven F. Costales for investigation. Judge Costales recommended dismissal due to complainants' failure to appear at hearings.
- The Court Administrator recommended a fine of P10,000.00 for each case, citing Gross Ignorance of the Law.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Ignorance of the Law: Judges are expected to be knowledgeable of fundamental legal principles. A civil action for malicious prosecution requires that the criminal case be finally terminated with an acquittal. Judge Suller's failure to recognize this basic principle constituted gross ignorance of the law.
- Dishonesty: Errors in citation, unless proven to be intentional, do not amount to dishonesty. The incorrect citation in this case was deemed a typographical error.
- Oppression: Judges must follow procedural rules strictly. Judge Suller's denial of the complainants' motions and appeals for being filed out of time was in accordance with the rules and did not constitute oppression.
- Anti-Graft and Corrupt Practices Act: Partiality and bad faith must be proven by clear and convincing evidence. No such evidence was presented in this case.
The Court emphasized that judges must maintain competence, integrity, and independence to uphold public confidence in the judiciary. While occasional errors of judgment are excusable, persistent misapplication of legal principles undermines the integrity of the courts.