A.M. No. 2268-MJ - Escarda vs. Manalo

The case involves an administrative complaint filed by Ricardo Escarda against Municipal Judge Jacinto Manalo of Coron, Palawan.
The complaint alleges improper judicial conduct on the part of Judge Manalo for not referring a complaint for slight physical injuries to the Lupon Tagapayapa, a barangay conciliation body.

The Katarungang Pambarangay Law (Presidential Decree No. 1508) was instituted to facilitate the amicable settlement of minor disputes at the barangay level, thereby reducing the burden on formal court dockets.
Circular No. 12, issued by the late Chief Justice Castro and later amended by Circular No. 22, directed judges to desist from receiving complaints that fall within the jurisdiction of the organized Lupon Tagapayapa once certification of their organization is received.
A Letter of Implementation from President Ferdinand E. Marcos, dated November 12, 1979, reinforced the directive by ordering “immediate implementation” of the system of amicable dispute settlement at the barangay level, further clarifying the operational mechanics of the conciliation process.
The directives stipulated that municipal judges are bound to follow the Rules of Court for cases properly cognizable by them until certification of the organization of the Lupon Tagapayapa is received.

The referral mechanism to the Lupon Tagapayapa was designed to become operative only after certification from the City and Municipal Development Officers confirming the organization of the barangay conciliation bodies.
In this case, the criminal case (Criminal Case No. 2041) involving slight physical injuries was filed before such certification was issued.
Consequently, Judge Manalo processed the case in accordance with the Rules of Court applicable to judicial proceedings, rather than referring it to the Lupon Tagapayapa.

Ricardo Escarda claimed that Judge Manalo improperly handled the case by refusing to refer it to the barangay conciliation mechanism as mandated by the Katarungang Pambarangay Law and the accompanying circulars.
Escarda’s allegation was grounded on the belief that the judicial officer’s actions were not in keeping with the intended role of the Lupon Tagapayapa in settling minor disputes.

The Court, through its resolution, emphasized that since the case was filed before the mandatory certification process of the organization of the Lupon Tagapayapa, the judge was duty-bound to handle it under the Rules of Court.
Relying on the directives set forth in Circular No. 12 and Circular No. 22, as well as the Letter of Implementation, the Court found that Judge Manalo acted in accordance with the law.
The administrative complaint for improper judicial conduct was thereby deemed without merit.

Whether Municipal Judge Jacinto Manalo committed improper judicial conduct by not referring the complaint for slight physical injuries to the Lupon Tagapayapa.
Whether the provisions of the Katarungang Pambarangay Law and the accompanying circulars required a municipal judge to refer cases to the Lupon Tagapayapa irrespective of the certification status concerning the organization of barangay conciliation bodies.
Whether the filing of the criminal case prior to the certification of the Lupon Tagapayapa exempted the judge from following the referral procedure under Presidential Decree No. 1508.
Whether adherence to the Rules of Court should prevail over the referral directive in cases where certification of the Lupon Tagapayapa has not yet been accomplished.