G.R. No. 130531 - People vs. Simon

A petition for a writ of habeas corpus was filed by Deputy Sheriff Abraham L. Ramirez, who had been arrested on June 27, 1985, for direct contempt of court.
The arrest followed an alleged disobedience to a writ of preliminary injunction issued in Civil Case No. 8682, and a previous order dated January 11, 1985, directing the demolition of certain improvements.
Judge Antonia Corpuz-Macandog executed the arrest through a handwritten note addressed to Brig. Gen. Alfredo Lim, ordering the immediate execution of the arrest.
Although Deputy Sheriff Ramirez was released on July 2, 1985 under orders from a higher court, the petition was converted into an administrative case to require the judge’s explanation for her conduct.

Complainant Liwayway B. Samson filed a damage complaint in Civil Case No. 11559 on September 28, 1984, against multiple defendants, with summonses served shortly after.
Various pleadings and motions ensued, including defendants’ answers, a motion to declare one defendant in default, and multiple motions by complainant seeking resolution of the pending issues.
In her comment, Judge Corpuz-Macandog asserted that the motion to declare default had been resolved within the allowable period and dismissed the letter-complaint as malicious and intended to malign her.
As the controversy regarding the proper service of summons and the dating of judicial orders emerged, she eventually inhibited herself from hearing the case, which was reassigned to another judge.

In a sworn letter dated April 28, 1986, Victoria L. Torres charged the judge with ignorance of the law, graft, and a willful distortion of the law for pecuniary motives.
Among the allegations were the indiscriminate issuance of restraining orders without hearings, repeated orders even after prescribed periods, and unconstitutional actions against sheriffs and attorneys-in-fact.
Torres also accused the judge of acting in controversial ejectment cases, particularly those involving the “Maysilo Estate.”
In response, Judge Corpuz-Macandog defended her actions as measures to maintain the status quo in pending cases and explained the issuance and subsequent recall of the arrest and restraining orders.

Complainant Esperanza Lazaro alleged that the judge improperly failed to decide Civil Case No. C-9831 for over 18 months, even while drawing her salary as the case remained pending.
The complaint further charged the judge with falsification by certifying that all cases should be decided within three months from submission.
In her answer, Judge Corpuz-Macandog contended that no record indicated formal submission of the case for decision and that the defendant had not been present during proceedings.
She explained that the decision rendered on July 18, 1986, was made under perceived pressure and the peculiar warning received via telephone, rendering the complaint moot in her view.

Complainant Jesus Alba charged the judge with gross incompetence, partiality, and knowingly rendering an unjust decision in Criminal Case No. C-23987, involving a frustrated murder charge against an accused known as Cabel.
The decision acquitting the accused was promulgated on June 10, 1986, in circumstances where Alba and his counsel were absent, and Alba learned of it indirectly.
Judge Corpuz-Macandog, when required to comment, detailed her rationale—highlighting the lack of compelling evidence against the accused and proper evaluation of witness credibility.
She maintained that any alleged errors were part of her judicial reasoning and not indicative of malfeasance.

This matter involved an appeal in Civil Case No. C-12172 concerning an unlawful detainer, pending before Branch CXXI of the RTC of Caloocan City.
A transfer of the presiding judge (Judge Salvador J. Baylen) prompted defendants-appellees to seek consolidation or re-raffling of the case to avoid delay.
The motion was referred to Judge Corpuz-Macandog as the pairing judge, based on a note from Executive Judge Oscar M. Herrera.
Subsequent developments included a reversal of her earlier order and the designation of Judge Domingo M. Angeles as Acting Judge for Branch CXXI, which sparked further controversy regarding the proper scope of her authority.
Judge Corpuz-Macandog explained that her taking cognizance of the case was based on existing instructions and her formerly sanctioned authority—a fact later challenged due to procedural and jurisdictional issues.

Whether Judge Antonia Corpuz-Macandog’s actions—including issuing arrest orders and restraining orders—constitute misconduct in the performance of her official judicial duties.
Whether her justification for the arrest of Deputy Sheriff Ramirez, based on preserving “substantial justice” and the integrity of court orders, is legally tenable given the ministerial nature of enforcement by sheriffs.
Whether the delay in resolving or notifying parties in Civil Case No. 11559 and the alleged antedating of orders reflect a neglect of judicial duty and a failure to administer justice with reasonable dispatch.
Whether the decision rendered in Civil Case No. C-9831, allegedly made under undue pressure, coupled with the failure to ensure proper procedural notification, warrants disciplinary action.
Whether her actions in taking cognizance of and eventually deciding Civil Case No. C-12172 exceeded the bounds of her authority as the pairing judge and violated established procedural rules governing such referrals.
Whether any error in judicial appreciation (e.g., in Criminal Case No. C-23987) can, by itself, justify administrative sanctions absent evidence of malice, bad faith, or gross incompetence.