Case Digest (G.R. No. 197122)
Facts:
Abraham L. Ramirez v. Hon. Antonia Corpuz‑Macandog, Adm. Matter Nos. R‑351‑RTJ; R‑359‑RTJ; R‑621‑RTJ; R‑684‑RTJ; R‑687‑RTJ; and Adm. Matter No. 86‑4‑9987‑RTC, September 26, 1986, the Supreme Court En Banc, Per Curiam.
Judge Antonia Corpuz‑Macandog of the Regional Trial Court (RTC), Caloocan City, Branch CXX, was the subject of six separate administrative complaints alleging varying forms of misconduct in the performance of her judicial duties. The matters were filed directly with the Court and docketed as the administrative matters listed above.
The first case began as G.R. No. 71179, a petition for writ of habeas corpus filed June 29, 1985 by Deputy Sheriff Abraham L. Ramirez to secure his release after respondent issued an arrest order (dated June 27, 1985) for alleged direct contempt for enforcing an earlier writ of execution issued by Judge Socorro Tirona‑Liwag (Branch CXXIII). Ramirez was arrested pursuant to a handwritten note from respondent to Northern Police District Superintendent Brig. Gen. Alfredo Lim. The Court ordered Ramirez released on July 2, 1985 and then treated the petition as an administrative complaint (Adm. Matter No. R‑351‑RTJ), requiring Judge Macandog to comment.
Adm. Matter No. R‑359‑RTJ arose from Liwayway B. Samson’s civil case (Civil Case No. 11559) assigned to respondent. Complainant alleged respondent failed to act on motions, particularly a motion to declare a co‑defendant in default (filed November 29, 1984) and thus delayed setting the case for pretrial. Respondent asserted the motion was noted for study and resolved March 1, 1985, and later inhibited herself from the case; complainant alleged the March 1 order was antedated and additionally faulted the judge for not ordering service of the third‑party complaint.
Adm. Matter No. R‑621‑RTJ (complaint of Victoria L. Torres) charged respondent with issuing restraining orders and preliminary injunctions without hearings or beyond the statutory 20‑day restraining period, interfering with writs of execution from co‑equal RTC branches, and for citing sheriffs and attorneys for contempt (including Ramirez). Respondent denied the allegations, explaining the injunctions were to preserve issues of ownership and that arrests were curative measures; the arrest order against Torres herself was later recalled as moot after a certiorari action (AC‑G.R. No. 09162‑SP) required comment.
Adm. Matter No. R‑684‑RTJ (complaint of Esperanza Lazaro) alleged respondent failed to decide Civil Case No. C‑9831 for more than 18 months after submission for decision. Complainant later manifested a desire to withdraw the complaint, but the Court still required an explanation. Respondent answered that the case had not clearly been submitted for decision and admitted that, following telephone calls implying pressure from a relative of a national official, she decided the case in favor of Mrs. Lazaro to avoid further calls, stating she “had no recourse” owing to the political climate.
Adm. Matter No. R‑687‑RTJ (complaint of Jesus Alba) challenged respondent’s acquittal in a criminal case (People v. Cabel), claiming she erred in evaluating evidence and failed to notify the offended party of promulgation. Respondent defended the merits of her evidentiary assessment and the decision.
Finally, Adm. Matter No. 86‑4‑9987‑RTC concerned Judge Macandog’s actions as the pairing judge in Branch CXXI after the transfer of Judge Salvador J. Baylen. A motion to consolidate or re‑raffle Civil Case No. C‑12172 was referred to respondent as pairing judge. Although she initially denied the consolidation motion, she later rescinded and considered the case submitted for decision and ultimately rendered judgment (May 15, 1986) over the plaintiff’s vigorous objection and request that the question be referred to the Court Administrator and ultimately to the Court En Banc. The Court En Banc on April 24, 1986 had designated Judge Domingo M. Angeles as Acting Judge of Branch CXXI; on July 8, 1986 it directed Judge Baylen to decide the case, required Macandog to explain why she should not be disciplined, and declared her decision null and voi...(Subscriber-Only)
Issues:
- Whether mere errors in judgment or alleged failure to notify an offended party of decision promulgation constitute administrative misconduct warranting discipline.
- Whether events such as release of an arrestee, recall of an arrest order, or withdrawal of a complaint render the corresponding administrative cases moot or require dismissal.
- Whether issuance of arrest orders (including a handwritten request to a police chief) and the use of injunctions to restrain writs of execution from co‑equal courts constitute misconduct warranting disciplinary sanctions.
- Whether delay in acting on motions and failure to ensure service of process constitute culpable delay and sanctionable lapse.
- Whether taking cognizance and deciding a case beyond the limited authority of a pairing judge (despite objection and pending referral) constitutes misconduct warranting removal.
- Whether respondent’s admission that...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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