A.M. No. 97-9-94-MTCC - Marquez vs. Manigbas

Atty. Reynaldo Q. Marquez filed a complaint against Judge Arcadio I. Manigbas of the Municipal Trial Court in Cities (MTCC), Lipa City, alleging violations of the Code of Judicial Conduct.
The complaint centered on three allegations:

Allowing his wife, Atty. Isabelita Bathan-Manigbas, to appear in his sala despite her having at least twenty pending cases;
Undue delay in the resolution of Civil Case No. 94-2665; and
Alleged maneuvering in the designation of Judge Norberto P. Mercado as his Assisting Judge.

In his defense, Judge Manigbas asserted that due to the single-sala configuration of the MTCC in Lipa City, it was inevitable that cases handled by his wife would be lodged in his court.
To avoid any appearance of impropriety, he explained that he abstained from presiding over cases involving his wife and that those matters were instead assigned to his Assisting Judge, Judge Norberto P. Mercado.
He further denied any undue delay in resolving Civil Case No. 94-2665 by explaining that while the case was resolved ninety-six (96) days after submission, the delay was attributable to an unprecedented influx of over seven hundred (700) additional cases due to the expansion of jurisdiction, which increased his overall caseload dramatically.

Judge Manigbas maintained that he did not “maneuver” the designation of Judge Mercado as his Assisting Judge.
Instead, he explained that Judge Mercado himself initiated a request for designation, citing his own light caseload in his regular court, and subsequently petitioned the Executive Judge of Lipa City.
The designation was later validated through a series of written communications and administrative orders, including A.O. No. 144-95, issued by Chief Justice Andres R. Narvasa.
The records, including excerpts from transcript stenographic notes, revealed that in instances where Atty. Isabelita Bathan-Manigbas participated as counsel, the cases were indeed heard by Judge Mercado, not by Judge Manigbas.

The complaint was referred to Retired Justice Pedro A. Ramirez, who conducted an investigation and subsequently recommended the dismissal of Judge Manigbas based on the allegations.
The Office of the Court Administrator (OCA) endorsed the investigation report, giving credence to the violations alleged by the complainant.
Despite these findings, the records indicated that the allegations were either based on mere insinuations or on administrative necessities rather than on any direct violation or misconduct by Judge Manigbas.

Whether Judge Manigbas violated the Code of Judicial Conduct by allowing his wife to appear in his sala despite her handling numerous cases.
Whether there was an undue delay in the resolution of Civil Case No. 94-2665, considering the circumstances of the expanded caseload.
Whether Judge Manigbas manipulated the designation of Judge Norberto P. Mercado as his Assisting Judge for any improper purpose.