Title
Arpon vs. De la Paz
Case
A.M. No. 41-MJ
Decision Date
May 28, 1975
Judge dismissed libel case after jurisdictional error, corrected promptly; no bad faith found, admonished for greater care.

Case Summary (A.M. No. 41-MJ)

Background of the Case

On June 4, 1971, Mrs. Clementina L. Oballo filed a criminal complaint for libel against complainant Alfredo Arpon in the municipal court. That same day, Judge De la Paz conducted a preliminary examination, determining there was a prima facie case against Arpon and issuing an arrest warrant. This sequence of events occurred quickly, culminating in the serving of the warrant on June 9, 1971, during which Arpon was detained but not incarcerated.

Issues Concerning Bail and Preliminary Investigation

Upon being informed of his bail eligibility, Arpon sought assistance from his relatives, who arrived the following day with a bail bond that was initially rejected by the judge’s clerk. After being permitted to search for new bondsmen, Arpon successfully filed a bail bond on June 11 and was released. Following this, the preliminary investigation was scheduled for June 16 but was rescheduled due to Arpon’s request to postpone for personal reasons.

Dismissal of the Case

On July 19, 1971, the date set for the postponed preliminary investigation, Judge De la Paz dismissed the libel case, recognizing that under Republic Act No. 4363, he lacked jurisdiction to conduct a preliminary investigation for written defamation matters. This dismissal was made without legal representation for Arpon. Subsequently, the Assistant Provincial Fiscal filed a reconsideration motion against the dismissal, which the judge denied on April 19, 1972.

Evaluation of Judicial Conduct

Upon investigation, the Court identified shortcomings in Judge De la Paz's knowledge of his jurisdiction. While it was acknowledged that he had acted outside of his jurisdiction, he demonstrated prompt corrective action upon realizing the error, and the absence of bad faith was noted. The Court emphasized that while judges must understand the limits of their jurisdiction, there may be i

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