Title
Manalo vs. Demaala
Case
A.M. No. 1906-MJ
Decision Date
May 13, 1981
A judge is suspended for three months without pay and ordered to repay debts in installments, emphasizing the judiciary's need for integrity and accountability.
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Case Digest (G.R. No. 170233)

Facts:

  • Josephine Lucio Manalo filed an administrative complaint against Hon. Clarito Demaala, a Municipal Judge in Aborlan, Palawan, on January 8, 1981.
  • The complaint was based on Demaala's alleged failure to pay a debt of P10,000 stemming from a transaction in December 1972.
  • Manalo sold a Toyota Mini bus to Demaala for P12,000, with a downpayment of P2,000 and ten monthly installments of P1,000 starting April 30, 1973.
  • After the downpayment, Demaala did not make further payments despite multiple demands from Manalo.
  • Demaala sold the vehicle to a third party and claimed it had defects, specifically defective piston rings, making it unusable for public transport.
  • He argued that a verbal agreement existed with Manalo, stating he would only continue payments if the vehicle was in good condition.
  • Manalo contested this claim, asserting that Demaala, being knowledgeable in law, should have formalized any conditions in writing.
  • The case was investigated by Executive Judge Eufrocinio S. dela Merced, who found the sale and payment terms undisputed and ruled that Demaala's claims did not absolve him of his payment obligation.

Issue:

  • (Unlock)

Ruling:

  • Yes, Judge Clarito Demaala willfully failed to pay his just debts to Josephine Lucio Manalo.
  • Yes, the failure to pay a just debt is a valid ground for disciplinary a...(Unlock)

Ratio:

  • The court determined that Demaala's acknowledgment of his debt and his inaction in settling it constituted willful neglect of his obligations.
  • Under Section 36(b) of Presidential Decree No. 807, willful failure to pay just debts is grounds for disciplinary action.
  • Demaala's prolonged inaction reflected poorly on his character as a public official.
  • Judges are expected to demonstrate integ...continue reading

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