A.M. No. RTJ-92-876 - State Prosecutors vs. Muro

Respondent Judge Manuel T. Muro motu proprio dismissed eleven (11) criminal cases against Mrs. Imelda Marcos for alleged violations of Central Bank foreign exchange restrictions, relying solely on newspaper reports of lifted restrictions characterized as “hearsay evidence, twice removed.”
The dismissals were made without awaiting any motion to quash from the defense and without affording the prosecution an opportunity to be heard, thereby resulting in summary disposition of the cases.

On September 19, 1994, the Supreme Court issued a Per Curiam Decision declaring the respondent’s actions as gross ignorance of the law, warranting his dismissal from the service, cancellation of eligibility, forfeiture of leave credits and retirement benefits, and disqualification from re-employment in government.
The Court emphasized that summary dismissals without due process—particularly depriving the prosecution of a hearing—constitute a blatant denial of elementary due process and are indicative of bad faith and partiality.

Respondent filed a motion for reconsideration, to which state prosecutors (complainants) filed comments and rejoinders; two associations sought—but were denied—leave to intervene as amici curiae.
The respondent argued absence of corrupt intent, highlighting his impeccable academic record (magna cum laude, valedictorian, sixth in the Bar), and tendered a “solemn commitment” to adhere strictly to the Canons of Judicial Ethics in the future.

Whether the motu proprio dismissal of eleven criminal cases—based on inadmissible hearsay and without affording the prosecution a hearing—constituted gross ignorance of the law amounting to judicial misconduct.

Whether the penalty of dismissal from service should be maintained or modified in light of respondent’s prior unblemished service, contrition, pledges of ethical future conduct, and the complainants’ softened stance.