G.R. No. L-32191 - Manaois vs. Brown

Complainant Abraham L. Mendova accused Judge Crisanto B. Afable of ignorance of the law in handling Criminal Case No. 2198-98, involving a complaint for slight physical injuries committed by Roberto Q. Palada.
The accusation stemmed from the judge’s dismissal of the criminal case on the ground of prescription, specifically for a light offense which, under the Revised Penal Code, prescribes in two months.

On February 15, 1998, it was alleged that Roberto Q. Palada committed the crime of slight physical injuries.
On February 18, 1998, Mendova filed a complaint with the Office of the Barangay Chairman at Poblacion, San Julian, Eastern Samar.
Certification by Barangay officials confirmed that the complaint was filed and that hearings were set (March 16, 22, and 29, 1998) though no amicable settlement was reached.

On May 4, 1998, Mendova elevated his complaint by filing Criminal Case No. 2198-98 with the Municipal Circuit Trial Court of San Julian-Sulat, Eastern Samar.
On November 3, 1998, Judge Afable rendered his decision dismissing the case on the ground of prescription, reasoning that more than two months had elapsed since the offense.

On July 1, 1999, Mendova filed an affidavit-complaint alleging that the judge had displayed ignorance of the law by not applying Section 410(c) of Republic Act No. 7160 (The Local Government Code of 1991), which provides for the suspension of the prescriptive period during mediation or conciliation proceedings.
On July 7, 1999, an administrative complaint was also filed with the Office of the Court Administrator.
Respondent Judge Afable, in his comment, admitted that an error was made due to a “mental lapse” caused by heavy workload, noting that it was his first such mistake in 10 years of service.

The Office of the Court Administrator found the judge remiss in his adjudicatory functions and recommended a fine of ₱3,000.00, coupled with a warning against a recurrence.
The evaluation stressed the importance of judges’ complete knowledge of internal rules and the law in ensuring public confidence in the judicial system.

On February 13, 2002, the Court ordered that the case be docketed as an administrative matter and invited both parties to manifest whether the decision would be based solely on the pleadings already filed.
Ultimately, the Court noted that the complainant had not exhausted the available judicial remedies—specifically, a motion for reconsideration—before resorting to administrative prosecution.

Whether the administrative complaint against Judge Afable for dismissing the criminal case on prescription grounds can proceed given that judicial remedies were available but not exhausted by the complainant.
Whether the judge’s reliance on the rule on prescription amounted to ignorance of the law or was merely an error of judgment.

Whether the complainant adequately demonstrated that the provisions of Section 410(c) of RA 7160 should have been applied to suspend the prescriptive period.
Whether the absence of proof regarding Mendova’s receipt of the Certification to File Action undermines his argument against the dismissal on prescription.

Whether the admitted error by Judge Afable, due to heavy workload and a “mental lapse,” warrants administrative sanctions.
Whether such an error, absent any indication of bad faith or malice, is sufficient to undermine his judicial decision.