Case Digest (A.M. No. MTJ-23-014 [Formerly JIB FPI No. 21-024-MTJ) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In A.M. No. MTJ-23-014, Judge Sharon M. Alamada-Magayanes, Vice-Executive Judge of MTCC Branch 3 in Calamba, Laguna, filed on June 1, 2021 an administrative complaint against Executive Judge Leah Angeli B. Vasquez-Abad of Branch 1, charging Gross Ignorance of the Law and Rules of Procedure for dismissing three newly filed criminal informations before their raffle and for assessing probable cause on an unraffled bail application. Judge Abad defended her motu proprio dismissals as good-faith compliance with pandemic-era circulars and recalled her orders upon clarification from the Court Administrator. In A.M. No. MTJ-23-015, Judge Abad counter-filed against Judge Alamada and two court personnel (Rachel Worwor-Miguel and Beverly De Jesus), alleging Dishonesty, Misconduct, and Code of Judicial Conduct violations arising from the employment and separation of a job-order driver, Sandy Eraga, and disputed salary withdrawals from his Land Bank ATM card. In A.M. No. MTJ-24-026, Judges Ab Case Digest (A.M. No. MTJ-23-014 [Formerly JIB FPI No. 21-024-MTJ) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Consolidation and Parties
- Four administrative cases were consolidated before the Supreme Court En Banc on April 11, 2024:
- A.M. No. MTJ-23-014 (JIB FPI No. 21-024-MTJ): Hon. Sharon M. Alamada-Magayanes (Vice-Executive Judge, Branch 3, MTCC Calamba) vs. Hon. Leah Angeli B. Vasquez-Abad (Executive Judge, Branch 1, MTCC Calamba).
- A.M. No. MTJ-23-015 (JIB FPI No. 21-032-MTJ): Judge Vasquez-Abad vs. Judge Alamada-Magayanes, Clerk of Court Rachel Worwor-Miguel, and Stenographer Beverly De Jesus (all of Branch 3).
- A.M. No. MTJ-24-026 (JIB FPI No. 21-033-MTJ): Judge Vasquez-Abad and Presiding Judge Eric Sakkam (Branch 2) vs. Judge Alamada-Magayanes.
- A.M. No. MTJ-24-027 (JIB FPI No. 21-042-MTJ): Judge Alamada-Magayanes vs. Judges Sakkam and Vasquez-Abad.
- Core Allegations and Procedural History
- Alamada’s Complaint (A.M. MTJ-23-014)
- Alleged that Executive Judge Abad motu proprio dismissed three criminal cases and assessed probable cause on bail applications before raffle, violating Rules on Summary Procedure, OCA Circulars, and her limited adjudicatory power.
- Sought preventive suspension for Gross Ignorance of Law and Rules.
- Judge Abad’s Reply claimed good faith, reliance on pandemic-era OCA Circulars (Nos. 33-2020, 89-2020, 94-2020), and immediate recall of her dismissal orders upon clarification from the Court Administrator.
- Abad’s Cross-Complaint (A.M. MTJ-23-015)
- Based on Sinumpaang Salaysay of JO worker Sandy Eraga, accused Judge Alamada of misappropriating his LBP ATM cash card and withdrawals of his LGU-employed salary after his resignation; charged Alamada with Dishonesty, Misconduct, and Code of Judicial Conduct violations.
- Alleged supporting “letter-complaint” was unverified to circumvent Rule 140, but later supplemented by verified complaints and affidavits.
- Included Clerk Worwor-Miguel and Stenographer De Jesus as respondents for certifying payroll registers.
- Complaints among Colleagues (JIB FPI Nos. 21-033 and 21-042)
- Judges Abad and Sakkam wrote letters against Alamada for Conduct Unbecoming, discourteous and demeaning remarks during raffles, and personal insults to the Clerk of Court.
- Alamada counter-filed for Gross Ignorance of Law, accusing them of unverified filings, revenge, and unauthorized notarizations (Circular 1-90, Nate v. Contreras).
- OED and JIB Actions
- The Office of the Executive Director (OED) issued Reports recommending:
- Dismissal of Abad’s gross-ignorance complaint for lack of merit (MTJ-23-014).
- Full investigation of Alamada’s misappropriation charges (MTJ-23-015).
- Dismissal of letters-complaints against Alamada for lack of evidence (MTJ-24-026, MTJ-24-027).
- The Judicial Integrity Board (JIB) issued Reports and Recommendations ranging from dismissal, admonition, re-docketing as regular matters, to preventive suspension and severe penalties against Alamada and her staff.
Issues:
- Liability of Executive Judge Vasquez-Abad
- Whether Abad grossly ignored the law and rules by dismissing three criminal cases pre-raffle and acting on bail applications outside her adjudicatory power.
- Whether pandemic-era OCA Circulars justified her actions.
- Liability of Presiding Judge Alamada-Magayanes
- Whether Alamada falsified payroll registers of JO worker Eraga and misappropriated his salary by retaining and using his LBP ATM cash card.
- Whether she committed Serious Dishonesty, Gross Misconduct, Commission of Crimes Involving Moral Turpitude, and NCJC violations.
- Liability of Colleagues Sakkam and Abad
- Whether filing unverified letters and administering oaths violated ethical rules and beyond their judicial duties.
- Whether these acts constituted Gross Ignorance of Law or NCJC breaches.
- Liability of Court Personnel
- Whether Clerk Worwor-Miguel and Stenographer De Jesus, by signing payroll registers under Alamada’s instruction, falsified official documents and committed Serious Dishonesty.
- Whether stenographer Agoncillo is liable for taking and returning Eraga’s cash card.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)