Facts:
Hon. Sharon M. Alamada, Vice-Executive Judge and Presiding Judge of Branch 3, MTCC, Calamba City, Laguna, filed a complaint dated June 1, 2021 against
Hon. Leah Angeli B. Vasquez-Abad, Executive Judge and Presiding Judge of Branch 1, MTCC, Calamba City, Laguna, alleging Gross Ignorance of the Law and Rules of Procedure after Judge Abad, on April 22, 2021, motu proprio dismissed three of four criminal informations filed April 20, 2021 against Jeffrey Ostil Tamayo prior to raffle while Tamayo had applied for bail; the remaining information was raffled to Judge Alamada and the accused pleaded guilty. Judge Alamada averred that Judge Abad exceeded executive authority in determining probable cause and in acting on bail applications before raffle, cited prior administrative directives and a purportedly inconsistent practice, and sought preventive suspension. Judge Abad countered that her orders were issued in good faith under pandemic-era circulars including
Administrative Circular No. 33-2020,
OCA Circular Nos. 89-2020 and 94-2020, and under her construed powers as Executive Judge, and that she promptly recalled her dismissal orders after seeking OCA guidance. Separately, on July 19, 2021 Judge Abad lodged a letter-complaint against Judge Alamada alleging
Dishonesty, Misconduct, and Violations of the Code of Judicial Conduct arising from the employment and payroll of Sandy Labarite Eraga, a purported JO/casual driver assigned to Judge Alamada who resigned September 24, 2020 yet allegedly continued to have salaries credited to an LBP cash card from which withdrawals were made; Judge Abad and others procured payroll registers, cash card records, Sinumpaang Salaysay, and other documents, and the Office of the Executive Director (OED) and the Judicial Integrity Board (JIB) conducted inquiries, recommended formal investigation in part, and ordered hearings where witnesses including Eraga, LBP and Hunter Security officials, and court personnel testified. During formal hearings Judge Alamada admitted signing multiple payroll registers, denied having possession of Eraga’s cash card, and maintained she acted to prevent delay of salaries; court stenographer Alona P. Agoncillo and court staff Ms.
Rachel Worwor-Miguel and Ms.
Beverly A. De Jesus testified about signing and processing payrolls and about withdrawals on instruction. The JIB consolidated four related administrative matters, conducted hearings, and made comprehensive recommendations; the case proceeded to the Court en banc, which rendered its decision on April 11, 2024 in Calamba City, Laguna.
Issues:
Was
Hon. Leah Angeli B. Vasquez-Abad administratively liable for Gross Ignorance of the Law and Rules of Procedure in dismissing three informations prior to raffle and in acting on bail applications? Was
Hon. Sharon M. Alamada administratively and disciplinarily liable for falsification of official documents, serious dishonesty, gross misconduct, commission of crimes involving moral turpitude, and violations of the New Code of Judicial Conduct arising from her certifications on payroll registers and alleged misappropriation of JO payroll withdrawals? Were
Rachel Worwor-Miguel,
Beverly A. De Jesus,
Alona P. Agoncillo, and
Hon. Eric Ismael P. Sakkam administratively liable for acts related to the payroll certifications, withdrawals, and notarization of complaints?
Ruling:
Ratio:
Doctrine: