Title
Supreme Court
Domingo vs. Reyes
Case
A.M. No. MTJ-98-1165
Decision Date
Jun 21, 1999
Judge Reyes erred by amending charges and assuming jurisdiction without transmitting records to the prosecutor, leading to a reprimand; Cabrera's complaint dismissed for lack of merit.

Case Digest (G.R. No. 231839)
Expanded Legal Reasoning Model

Facts:

  • Parties and Procedural Background
    • Complainant: Exequiel P. Domingo filed a complaint against:
      • Judge Luis Enriquez Reyes, presiding judge of the Municipal Trial Court (MTC) of Guiguinto, Bulacan.
      • Clerk of Court Erlinda Cabrera of the same court.
    • Allegations Against Respondents:
      • Against Judge Reyes: Grave abuse of discretion, misconduct, gross ignorance of the law, and acts unbecoming a judge.
      • Against Clerk Cabrera: Grave misconduct, conduct unbecoming a court employee, and conduct prejudicial to the best interest of the service.
  • Factual Background of the Underlying Criminal Cases
    • On September 4, 1996, criminal complaints were filed against complainant and a certain Engr. Benjamin Biascan for:
      • Robbery with slight physical injuries (Criminal Case No. 5528).
      • Malicious mischief (Criminal Case Nos. 5529 and 5530).
    • Respondent Judge’s Preliminary Investigation:
      • Conducted a preliminary investigation on the robbery with physical injuries charge.
      • Determined no prima facie case existed for that charge.
      • Found that the “larceny of the rings” alleged was not the primary motivation but an afterthought.
      • Directed the Guiguinto police to amend the robbery charge to one for theft and to file a separate complaint for the physical injuries.
      • Took cognizance of the resulting cases (Criminal Case Nos. 5573 and 5574) and issued arrest warrants against the complainant.
  • Allegations of Procedural Irregularities and Personal Motives
    • Complainant’s Contentions:
      • Respondent Judge assumed jurisdiction over the cases beyond what his powers allowed.
      • He should have refrained from handling the preliminary investigation since the certificates to file action were issued anomalously.
      • Failure to follow proper procedure regarding the lack of court orders requiring conciliation at the barangay level.
      • The initiation of filing criminal cases was allegedly induced by:
        • Respondent Clerk of Court.
        • Barangay Captain Jose Hilario of Sta. Rita, Guiguinto, Bulacan.
        • Lucita Nagal, president of the Masagana Homes Homeowners' Association.
    • Respondent Judge’s Defense:
      • Acknowledged ordering the amendment of the complaint but claimed it was the just and proper action.
      • Justified his act based on the silence of Rule 112 regarding situations where complaints for offenses cognizable by the Regional Trial Court reveal evidence for offenses within the municipality.
      • Admitted to overlooking his duty of transmitting the resolution of the preliminary investigation as mandated in Balagapo v. Duquilla, attributing the error to human imperfection.
      • Asserted that the filing of the complaint against him was an attempt to harass and coerce him into recusal.
    • Respondent Clerk of Court’s Defense:
      • Denied any misconduct or involvement with the criminal cases filed against the complainant.
      • Claimed that the complaint against her was malicious and intended solely to harass her.
  • Evaluation by the Office of the Court Administrator (OCA)
    • The matter was referred to the OCA on July 7, 1997, for its evaluation.
    • Findings of the OCA Report (dated April 15, 1998):
      • The judge erred in ordering the amendment of the complaint and taking cognizance of the cases.
        • He failed to follow Section 5, Rule 112 of the Rules of Court, which mandates that within ten (10) days after the conclusion of the preliminary investigation, the resolution and entire records must be transmitted to the Provincial Prosecutor.
      • The error was due to human frailty rather than malice or intent to injure.
      • The respondent judge’s error did not rise to the level of grave abuse of discretion, misconduct, or act unbecoming a judge.
      • His repentant attitude and record of good standing as evidenced by this being his first complaint mitigated his administrative liability.
      • Recommendation:
        • The respondent judge be reprimanded.
        • The complaint against the respondent clerk of court be dismissed due to lack of merit.
  • Final Court Resolution
    • In a resolution dated October 7, 1998:
      • The complaint against the clerk of court was dismissed.
      • The respondent Judge Reyes was reprimanded for ignorance of the law.
      • The judge was warned that any future occurrence of a similar offense would be dealt with more severely.

Issues:

  • Whether respondent Judge Reyes committed grave abuse of discretion, misconduct, and gross ignorance of the law during the preliminary investigation.
    • Whether his action of ordering the amendment of the complaint and assuming jurisdiction over the cases was proper.
    • Whether the omission to transmit the resolution of the preliminary investigation as required by Section 5, Rule 112, constitutes an act of misconduct.
  • Whether respondent Clerk Cabrera committed misconduct or conduct unbecoming a court employee as alleged by the complainant.
    • The sufficiency of evidence against her.
    • The implication of her alleged involvement in the filing of criminal cases against the complainant.
  • Procedural and Jurisprudential Issues
    • The proper application of Rule 112 of the Rules of Court regarding the ministerial duty of an investigating judge.
    • Whether judicial errors attributable to human imperfection, absent malice, warrant severe sanctions.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
Unlock Full Case Digest

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.

About Privacy Terms