Case Digest (A.M. No. MTJ-91-622)
Facts:
Atty. Manuel T. Ubarra v. Judge Luzviminda M. Mapalad, A.M. No. MTJ-91-622, March 22, 1993, the Supreme Court En Banc, Per Curiam. The complaint arose from a letter-complaint filed 21 November 1991 by Atty. Manuel T. Ubarra on behalf of his client Juanito A. Calderon, charging respondent Judge Luzviminda M. Mapalad, Presiding Judge of the Municipal Trial Court (MTC) of Pulilan, Bulacan, with grave misconduct, knowingly rendering an unjust judgment, violations of the Canons of Judicial Ethics, and failure to decide within the mandated ninety-day period in Criminal Case No. 89-3905 (People v. Roberto Cruda) for Grave Threats.Calderon’s attached affidavit alleged that during the trial of Criminal Case No. 89-3905 he observed partiality by Judge Mapalad in favor of accused Roberto Cruda, who allegedly worked as respondent’s houseboy; that the case was submitted for decision on 27 March 1990; that Cruda married respondent’s youngest sister, Annabelle V. Manlangit, on 9 August 1991 in a ceremony solemnized by respondent; and that despite this relationship respondent did not inhibit herself in Criminal Case No. 89-3905 and promulgated judgment on 17 October 1991 acquitting Cruda. Calderon noted respondent had voluntarily inhibited herself earlier, on 7 September 1991, in a separate case (Criminal Case No. 90-4056) involving Cruda.
In her answer (filed 6 May 1992), respondent narrated efforts to reform and rehabilitate Cruda after discovering his disadvantaged background, admitted interceding to have other pending criminal actions against him withdrawn, and explained that when she presided over Criminal Case No. 89-3905 the familial relation that would later arise had not yet existed. She asserted the acquittal rested on a finding of pari delicto between complainant and accused, denied that she knowingly rendered an unjust judgment, but admitted she decided the case beyond the 90-day reglementary period and asked for leniency.
The Court Administrator referred the matter to Executive Judge Natividad G. Dizon of the RTC, Malolos, Bulacan, for investigation. The investigating judge held hearings, received evidence and, in a Report and Recommendation dated 1 February 1993, found respondent guilty of grave misconduct for rendering an unjust decision, guilt...(Pro-only)
Issues:
- Was respondent Judge Mapalad guilty of grave misconduct and disqualification for presiding over and rendering judgment in Criminal Case No. 89-3905 despite being related by affinity to the accused?
- Did respondent knowingly render an unjust judgment in Criminal Case No. 89-3905 such that criminal responsibility under Article 204, RPC, or equivalent administrative liability is established?
- Was respondent guilty of gross inefficiency or neglect of duty for failing to decide Criminal Case No. 89-3905 within the ninety-day reglementary period?
- Did respondent engage in conduct prejudicial to the best interest of the service by interceding in the settle...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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