Case Summary (A.C. No. 9684)
Background of the Case
The administrative complaint against the respondents stemmed from the information for libel prepared by Assistant City Prosecutor de Dios and approved by City Prosecutor Manabat. Respondent Villena served as the trial prosecutor and was accused of gross ignorance of the law for opposing the motion to quash, despite the MeTC's lack of jurisdiction. Boto's affidavit-complaint claims that the prosecution was negligent and that the required jurisdictional prescriptions were ignored.
Motion for Reconsideration
On October 22, 2013, Villena filed a Motion for Reconsideration, respectfully requesting that the Court either relieve him from liability or reduce the imposed fine. He expressed his belief that the actions leading to the penalty were not solely his fault and cited that the delays in prosecuting the motion were out of his control, as they relied heavily on the Lower Court's determination.
Response and Justifications
In his reconsideration plea, Villena acknowledged specific shortcomings in his handling of the case, including his assumption that the Lower Court would recognize and rectify its jurisdictional error without prompting. He clarified that his responses to the motions were not motivated by malice, and emphasized his commitment to his professional duties over his tenure as a prosecutor, detailing his otherwise exemplary record.
Court's Consideration
The Court recognized Villena's expression of contrition and noted that the penalty of a fine imposed previously would negatively impact his career trajectory, as it would remain on record potentially affecting future promotions or applications for higher positions. The Court emphasized that penalties should serve as a means of correction rather than punishment and showed willingness to acknowledge Villena's clean professional history and the lack of ill intent in his actions.
Resolution of the Motion
The Supreme Court resolved to partially grant Villena's Motion for Reconsideration,
...continue readingCase Syllabus (A.C. No. 9684)
Case Background
- This administrative case arises from a libel information filed against complainant Mary Rose A. Boto.
- The information was prepared by Assistant City Prosecutor Patrick Noel P. De Dios, who served as the investigating prosecutor.
- The information was subsequently approved by City Prosecutor Archimedes V. Manabat.
- Senior Assistant City Prosecutor Vincent L. Villena was assigned as the trial prosecutor at the Metropolitan Trial Court, Branch LXXIV, Taguig City.
Allegations Against Respondents
- Complainant Boto filed an Affidavit-Complaint against Villena, Manabat, and De Dios, accusing them of gross ignorance of the law.
- The allegations stemmed from the filing of the information and the opposition to the motion to quash, despite knowing that the MeTC lacked jurisdiction over the case.
Initial Decision of the Court
- In the September 18, 2013 Decision, the Court found:
- Senior Assistant City Prosecutor Vincent L. Villena liable for Ignorance of the Law and imposed a fine of Ten Thousand Pesos (P10,000.00).
- Assistant City Prosecutor Patrick Noel P. De Dios was reprimanded for negligence.
- City Prosecutor Archimedes V. Manabat was admonished to exercise greater care in reviewing a