G.R. No. 178789 - Lim vs. National Power Corp.

The Court emphasized that a judge must have continuous study of the law, be profoundly learned, and exhibit more than cursory acquaintance with statutes and rules.
Public confidence in the judiciary requires judges to avoid apparent deficiency in legal grasp and to administer justice with integrity and impartiality.

Complainants: State Prosecutors Nilo C. Mariano, George C. Dee, and Paterno V. Tac-an of the DOJ Panel of Prosecutors.
Respondent: Judge Manuel T. Muro, RTC Manila, Branch 54.
Allegations of ignorance of the law, grave misconduct, and violations of Code of Judicial Conduct Rules 2.01, 3.01, 3.02, based on these acts:

On August 13, 1992, motu proprio dismissal of eleven criminal cases (Crim. Nos. 92-101959 to 92-101969) against Imelda R. Marcos for violation of CB Circular No. 960.
Reliance solely on newspaper reports (Philippine Daily Inquirer and Daily Globe, August 11) of the President’s announcement lifting foreign exchange restrictions, without official publication of a repealing Central Bank Circular.
Claim that the lifting repealed CB Circular No. 960 and stripped the court of jurisdiction, leading to immediate dismissal and denial of prosecution’s right to be heard.
Failure to await publication, no motion to quash or comment required, precipitate action in disregard of due process, showing bias and partiality.

Argued the President’s announcement was total, absolute, immediately effective, and sufficient for judicial notice under Rule 129, Sec. 2.
Contended the saving clause of CB Circular No. 1353 did not cover cases under Circular No. 960.
Maintained a judge’s mistake in interpreting law is not proof of ignorance; remedy should be appeal, not administrative complaint.
Accused complainants of violating confidentiality by publishing the administrative case.

Noted that CB Circular No. 1318’s Section 111 expressly repealed Circular No. 960 but preserved pending cases under its saving clause; Circular No. 1353 carried forward that same exception.
Emphasized respondent’s precipitate dismissal without hearing reflected partiality and bad faith.

Supreme Court resolution (Dec. 9, 1993) referred the complaint to the Office of the Court Administrator.
Deputy Court Administrator’s report (Feb. 14, 1994) recommended findings.

Dismissed eleven cases motu proprio for lack of jurisdiction, relying on newspaper accounts of the lifting of foreign exchange restrictions.
Cited Supreme Court precedents (People v. Alcaras, Francisco, Pastor, Tamayo) that repeal of penal laws deprives courts of jurisdiction.

The CA granted certiorari, held respondent acted in excess of jurisdiction and grave abuse of discretion.
Found newspaper reports are not official publication; Circular No. 1353 published Aug. 27, effective Sept. 2, 1992.
Emphasized saving clause of Circulars 1318 and 1353 preserved pending actions.
Reversed respondent’s dismissal order and reinstated the criminal cases.

Did Judge Muro violate Code of Judicial Conduct Rules 2.01, 3.01, and 3.02 by dismissing the cases motu proprio?
Was it proper for the judge to take judicial notice of a law (CB Circular No. 1353) not yet officially published or in force?
Did the saving clauses of CB Circulars No. 1318 and No. 1353 preserve jurisdiction over the pending cases?
Did the motu proprio dismissal without hearing deny the prosecution due process and exhibit bias or partiality?
What administrative sanction, if any, should be imposed for gross ignorance or abuse of judicial power?