Facts:

• The case Esteban Ubongen vs. City Judge Toribio S. Mayo was decided on August 6, 1980, under A.M. No. 1255-CTJ.
• Complainant Esteban Ubongen filed a verified complaint against Judge Mayo following the acquittal of Paulino C. Lopez and two co-accused in Criminal Case No. 30665.
• The accused were charged with falsifying the signature of Francisca Ubugen on a document titled "Agreement," dated July 14, 1969.
• This document was allegedly used to transfer property rights after Francisca's death in 1972.
• Paulino Lopez presented the falsified document to the city assessor's office to facilitate property transfer at Lot 13, Block 7, Cabinet Hill, Baguio.
• The act caused harm to Francisca's successors-in-interest, including Esteban Ubongen.
• Judge Mayo acquitted the accused based on reasonable doubt, despite recognizing signature discrepancies.
• Ubongen's complaint argued that Judge Mayo failed to apply the legal presumption that the holder of a falsified document is presumed to be the forger.

Issue:

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Ruling:

• The Supreme Court ruled that Judge Mayo erred by not applying the legal presumption concerning the holder of a falsified document.
• The Court admonished him to exercise greater prudence and circumspection in his duties.
• Judge Mayo was reprimanded for attempting to mislead the Court regarding his findings.
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Ratio:

• The Court's argument was based on the principle that the holder of a falsified document is presumed to be the forger, supported by prior jurisprudence.
• Although Judge Mayo acknowledged the document's falsification, he failed to connect this acknowledgment to the culpability of Lopez and his co-accused, leading to an unjust acquittal.
• The Court note...continue reading