Case Summary (A.M. No. 97-9-94-MTCC)
Allegations Against Judge Manigbas
Judge Manigbas faces three major allegations: (a) allowing his wife, Atty. Isabelita Bathan-Manigbas, to represent clients in his court with multiple pending cases; (b) unduly delaying the resolution of Civil Case No. 94-2665; and (c) allegedly maneuvering the designation of Judge Norberto P. Mercado as his Assisting Judge.
Judge Manigbas' Defense
In response to the allegations, Judge Manigbas claims he had to accept the cases of his wife due to the single-court structure in Lipa City, where he actively inhibited himself from presiding over those cases, referring them to Judge Mercado instead. He argues that any perceived delay in the judicial process was due to a substantial increase in cases following the expansion of municipal court jurisdiction, asserting that he had no responsibility for such delays.
Investigation and Findings
The case was referred to Retired Justice Pedro A. Ramirez, who investigated the allegations. Justice Ramirez concluded that Judge Manigbas violated the Code of Judicial Conduct by allowing his wife to appear in his court, manipulating Judge Mercado's designation, and failing to resolve Civil Case No. 94-2665 timely. Justice Ramirez recommended the respondent's dismissal from service.
Court Administration's Evaluation
After reviewing Justice Ramirez's report, the Office of the Court Administrator (OCA) also recommended dismissal, doubting Judge Manigbas's claim that Judge Mercado independently sought the designation. However, no substantive proof indicated that Judge Manigbas presided over cases involving his wife.
Lack of Evidence to Support Complainant's Claims
The allegations were insufficiently supported by evidence. Even the complainant acknowledged that Judge Mercado heard the cases involving Atty. Isabelita Bathan-Manigbas. Respondent Judge reaffirmed that the assignment of these cases to Judge Mercado was handled by the Clerk of Court to uphold judicial propriety.
The Designation of Judge Mercado
Documentation demonstrated that Judge Mercado initiated his request to become an Assisting Judge to better manage the growing caseload at Judge Manigbas' court. Correspondence confirmed that this designation was formally approved and not manipulated by Judge Manigbas, supporting the notion that the judicial needs of Lipa
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Case Overview
- The case involves Atty. Reynaldo Q. Marquez as the complainant against Judge Arcadio I. Manigbas of the Municipal Trial Court in Cities (MTCC), Lipa City.
- The charges against Judge Manigbas include alleged violations of the Code of Judicial Conduct pertaining to:
- Allowing his wife, Atty. Isabelita Bathan-Manigbas, to appear in his courtroom despite having multiple pending cases.
- Undue delay in the resolution of Civil Case No. 94-2665.
- Maneuvering the designation of Judge Norberto P. Mercado as Assisting Judge.
Respondent's Defense
- Judge Manigbas maintained that the presence of his wife's cases in his court was inevitable due to the court being a single-sala institution.
- He claimed to have inhibited himself from presiding over cases involving his wife to avoid any impropriety.
- Concerning the delay in Civil Case No. 94-2665, he attributed the delays to an overwhelming increase in cases due to an expansion of municipal trial court jurisdiction.
- He denied any wrongdoing in orchestrating Judge Mercado's designation, asserting it was Judge Mercado's initiative.
Investigation Report Findings
- The complaint was referred to Retired Justice Pedro A. Ramirez for investigation.
- Justice Ramirez concluded that Judge Manigbas was liable for:
- Allowing his wife to practice in his court.
- Unduly delaying the resolutio