Case Digest (A.M. No. MTJ-03-1479)
Facts:
- Atty. Melencio A. Cea filed an administrative complaint against Judge Orlando C. Paguio of the Municipal Trial Court, Branch 1, Meycauayan, Bulacan.
- The complaint, dated January 23, 2001, accused Judge Paguio of violating the Code of Legal Ethics and the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019).
- The grievance arose from Criminal Cases Nos. 95-17285, 95-17286, and 95-17287, where Judge Paguio rendered a consolidated decision on July 3, 2000, convicting the accused, Alicia Cea Tecson, who is Atty. Cea's daughter.
- Atty. Cea, who also served as his daughter's counsel, alleged that Judge Paguio solicited a bribe of P100,000.00 in exchange for a favorable decision during several meetings at Ark's Restaurant in Marilao, Bulacan.
- Atty. Cea refused the alleged bribe and dared the judge to proceed with the promulgation, which resulted in his daughter's conviction on December 4, 2000.
- Judge Paguio denied the allegations, stating he did not know the complainant's residence or office and had no reason to extort money if the case was meritorious.
- The Office of the Court Administrator referred the case to the Executive Judge of the Regional Trial Court, Malolos, Bulacan, for investigation.
- The Executive Judge found Judge Paguio guilty of gross misconduct and recommended sanctions.
- The Supreme Court dismissed the complaint due to insufficient evidence but fined Judge Paguio P3,000.00 for the delay in promulgating the decision.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that there was no sufficient evidence to prove that Judge Paguio solicited a bribe from Atty. Cea.
- The complaint against Judge Paguio for gross misconduct was dismissed due to insufficient evidence. ...(Unlock)
Ratio:
- The Supreme Court found that the evidence presented by Atty. Cea, which included his oral testimony, his daughter's testimony, and a restaurant receipt, was insufficient to substantiate the allegations of bribery.
- The receipt did not indicate the identity of the individuals involved, and there was no corroborative testimony from disinterested witnesses such as restaurant employees.
- The Court emphasized that accusations of bribery require subst...continue reading
Case Digest (A.M. No. MTJ-03-1479)
Facts:
In the case of "Cea v. Paguio," Atty. Melencio A. Cea, the complainant, filed an administrative complaint against Judge Orlando C. Paguio of the Municipal Trial Court, Branch 1, Meycauayan, Bulacan. The complaint, dated January 23, 2001, accused Judge Paguio of violating the Code of Legal Ethics and the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019). The grievance stemmed from Criminal Cases Nos. 95-17285, 95-17286, and 95-17287, where the judge rendered a consolidated decision on July 3, 2000, convicting the accused, Alicia Cea Tecson, who is the complainant's daughter. Atty. Cea, who also served as his daughter's counsel, alleged that Judge Paguio solicited a bribe of P100,000.00 in exchange for a favorable decision during several meetings at Ark's Restaurant in Marilao, Bulacan. Feeling insulted, Atty. Cea refused and dared the judge to proceed with the promulgation, which resulted in his daughter's conviction on December 4, 2000. Judge Paguio denied the allegations, claiming he did not know the complainant's residence or office and had no reason to extort money if the case was meritorious. The Office of the Court Administrator referred the case to the Executive Judge of the Regional Trial Court, Malolos, Bulacan, for investigation. The Executive Judge found Judge Paguio guilty of gross misconduct and recommended sanctions...