Case Digest (A.M. No. MTJ-94-1012)
Facts:
Johan L.H. Wingarts and Ofelia A. Wingarts v. Judge Servillano M. Mejia, A.M. No. MTJ-94-1012, March 20, 1995, Supreme Court Second Division, Regalado, J., writing for the Court.
Complainants Johan (also referred to as Leo or John Leonardo A.) L.H. Wingarts and Ofelia A. Wingarts filed three separate administrative complaints against Judge Servillano M. Mejia, Municipal Trial Court (MTC) of Santa Maria, Pangasinan. The administrative charges arose from three related criminal prosecutions that were heard by respondent judge: Criminal Case Nos. 2663 and 2664 (filed by Col. Rodulfo Munar against Johan/Leo Wingarts for malicious mischief and grave threats, respectively) and Criminal Case No. 2696 (a countercharge by the Wingarts for usurpation of authority, naming Capt. Dominador Manuel and Col. Rodulfo Munar as accused).
In the first administrative complaint complainants accused the judge of malicious delay in Criminal Case No. 2663, alleging the matter lingered in his sala for one year and four months and was only dismissed by a decision dated June 8, 1994 after an ocular inspection of the burned premises. In the second complaint they charged incompetence, ignorance of the law and abuse of authority for the judge's taking cognizance of Criminal Case No. 2664 (grave threats) and issuing a warrant of arrest despite the asserted lack of prior barangay conciliation; that criminal case was later dismissed and endorsed to the barangay. The third complaint accused the judge of rendering an unjust decision in Criminal Case No. 2696 when he acquitted the accused military lawyers, finding their acts did not amount to usurpation of authority.
Respondent judge filed comments: he asserted he believed there had been substantial compliance with the Katarungang Pambarangay law (a barangay captain’s certification of confrontation and non-settlement was presented), maintained that the proceedings in the delay case were continuous and that the decision was issued about one month after submission, and defended his acquittal in No. 2696 as based on evidence and law (citing DND Circular No. 2, a subsequent permit obtained, a manifestation from the Assistant Provincial Prosecutor, and the failure of the prosecution to prove criminal intent).
The Office of the Court Administrator (OCA), in a memorandum dated December 27, 1994, found the first charge meritorious because under R.A. No. 7160 (Local Government Code of 1991) (Art. 408(c) and Sec. 412(a)) offenses punishable by imprisonment not exceeding one year or a fine not exceeding P5,000 require prior barangay conciliation and grave threats fall within that purview; thus the judge should have remanded the case to the lupon rather than taking cognizance and issuing a warrant. The OCA judged the delay charge to be not malicious or deliberate, attributing postponements to absences of counsel or the fiscal and noting the case was decided one month after submission; and it recommended no finding of bad faith as to the acquittal in No. 2696, describing the elements necessary to prove a judge knowingly rendered an unjust judgment.
The Supreme Court reviewed the records, agreed with the OCA that respondent judge was liable for incompetence and ignorance of the law for taking cognizance of Criminal Case No. 2664 despite the statut...(Subscriber-Only)
Issues:
- Did Judge Servillano M. Mejia commit an administrative offense by taking cognizance of Criminal Case No. 2664 despite the alleged lack of prior barangay conciliation (a precondition under the Katarungang Pambarangay law)?
- Did Judge Mejia commit malicious delay in the administration of justice in Criminal Case No. 2663?
- Did Judge Mejia knowingly render an unjust judgment in Criminal Case No. 2696 (i.e., was his acquittal motivated by bad faith such that it amo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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