Title
IN RE: Liangco
Case
A.M. No. 99-11-158-MTC
Decision Date
Aug 1, 2000
A Municipal Trial Court judge in Pampanga was suspended for six months without pay for improperly handling jueteng cases, breaching Supreme Court Circular No. 7 and compromising public trust in the judiciary.
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Case Digest (A.M. No. 99-11-158-MTC)

Facts:

  • An administrative case originated from a Memorandum dated August 17, 1999, by Executive Judge Pedro M. Sunga of the RTC, Branch 42, San Fernando, Pampanga.
  • The Memorandum requested information from Judge Daniel B. Liangco regarding the assignment of twenty-nine cases for violation of Presidential Decree No. 1602 (Jueteng) filed in July 1999.
  • Juanita Flores, Clerk of Court II of the MTC, reported irregularities in the assignment of these cases.
  • Judge Liangco responded on August 20, 1999, stating all twenty-nine cases were assigned to Branch 1, which he presided over.
  • Judge Sunga later found that fifty-five jueteng cases had been filed, with fifty-three assigned to Branch 1, raising concerns about the fairness of the assignment process.
  • Judge Liangco explained that the assignment aimed to allow detained accused to post bail without waiting for raffle dates, but this was met with skepticism.
  • Clerk Flores revealed that jueteng cases were not being raffled and were automatically retained by Branch 1.
  • Following investigations, the Office of the Court Administrator (OCA) recommended holding Judge Liangco accountable for improper case assignments.
  • On November 9, 1999, the Court En Banc adopted the OCA's recommendations, leading to further explanations from Judge Liangco.
  • Ultimately, the Court found serious breaches of duty and imposed a six-month suspension instead of dismissal.

Issue:

  • (Unlock)

Ruling:

  • Yes, the Court ruled that Judge Liangco violated Supreme Court Circular No. 7 by directly assigning cases for violation of P.D. 1602 to his branch without a proper raffle.
  • The Court imposed a six-month suspension without p...(Unlock)

Ratio:

  • The Court emphasized the necessity for judges to maintain integrity and impartiality, as their actions significantly affect public confidence in the judiciary.
  • Judge Liangco's practice of assigning cases without a proper raffle was a clear violation of Supreme Court Circular No. 7, which mandates fair and transparent case assignments.
  • The statistical improbability of having fifty-three out of fifty-five cases assigned to one branch raised s...continue reading

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