G.R. No. 187056 - Del Rosario vs. Ferrer

On May 3, 2000, complainant Capistrano Obedencio, Jr., and his wife filed with the Provincial Prosecutor’s Office in Cagayan de Oro City a criminal complaint for rape against their daughter’s uncle, Dexter Z. Acenas, alleging the victim, Licel Acenas Obedencio, was raped at age 11.
After a preliminary investigation—at which the accused did not appear—the case was set for trial before Judge Joaquin M. Murillo, RTC, Branch 26, Medina, Misamis Oriental (Criminal Case No. 1401-M).

On May 25, 2001, following Licel’s abduction from her home, complainant sought a copy of the warrant of arrest against Acenas.
He learned that the case had been dismissed on May 22, 2001, without notice to him, his wife, or their counsel.

Respondent judge reported that on May 22, 2001, Assistant Provincial Prosecutor Hallazgo requested a hearing; Licel, accompanied by her maternal grandparents and the prosecutor, affirmed an affidavit of desistance and recanted the rape allegations, claiming parental pressure motivated the complaint.
Judge Murillo dismissed the case for desistance. Complainant alleged serious irregularities: no subpoenas or notices to the parents or counsel, undue influence on the minor, and familiarity among the prosecutor, grandparents, and accused.
The Office of the Court Administrator (OCA) found respondent judge liable for ignorance of the law and recommended a reprimand.
The Supreme Court took cognizance of the letter-complaint (A.M. No. RTJ-03-1753) and the OCA report.

Did Judge Murillo commit grave error or ignorance of the law by dismissing the rape case based solely on a minor’s affidavit of desistance and recantation without notice to her parents or counsel?
Do his actions warrant administrative liability under the Code of Judicial Conduct, and what penalty is appropriate?