Case Summary (A.M. No. MTJ-02-1402)
Allegations and Proceedings
In an affidavit-complaint dated July 1, 1999, Mendova accused Judge Afable of ignorance of the law for dismissing his criminal case on the grounds of prescription. Mendova outlined that his initial complaint was lodged with the Barangay Chairman on February 18, 1998, following an incident on February 15, 1998. Despite an attempt at amicable settlement, the case progressed to the Municipal Circuit Trial Court, where it was docketed on May 4, 1998.
Dismissal of the Case
On November 3, 1998, Judge Afable dismissed the case, concluding that it had already prescribed, as the filing was beyond the two-month period allowed for light offenses under Article 90 of the Revised Penal Code. Mendova claimed that the judge's failure to consider the interruption of the prescriptive period due to the barangay mediation process, as stipulated in Section 410(c) of the Local Government Code of 1991, indicated ignorance of the law.
Response from Judge Afable
In his comment on the complaint, Judge Afable acknowledged that his dismissal of the case was incorrect and attributed this error to a lapse in judgment stemming from his heavy workload. He expressed regret over the incident, stating that it was his first mistake in his ten-year tenure as a judge.
Evaluations and Recommendations
The Office of the Court Administrator conducted an evaluation and found Judge Afable guilty as charged. The Deputy Court Administrator recommended a fine of P3,000.00 and issued a warning regarding the consequences of future similar conduct, emphasizing the importance of judges maintaining public confidence by being knowledgeable about the law.
Judicial Review and Administrative Complaint
The Court clarified that an administrative complaint is not a substitute for available judicial remedies. It expressed concern that holding judges accountable for every erroneous decision would undermine their ability to conduct trials without fear of harassment. The Court highlighted that only gross, deliberate errors or actions made in bad faith may warrant administrative sanctions against judges.
Prematurity of the Administrative Complaint
The Court concluded that Mendova's administrative complaint was premature because h
...continue readingCase Syllabus (A.M. No. MTJ-02-1402)
Case Background
- On July 1, 1999, Abraham L. Mendova filed an affidavit-complaint against Judge Crisanto B. Afable, who presided over the Municipal Circuit Trial Court of San Julian-Sulat, Eastern Samar.
- The complaint centered on the judge's dismissal of Criminal Case No. 2198-98, which involved slight physical injuries allegedly inflicted by Roberto Q. Palada on February 15, 1998.
- Mendova filed his initial complaint with the Barangay Chairman on February 18, 1998, and later filed a formal complaint in court on May 4, 1998.
Judicial Proceedings
- The Barangay Chairman and Pangkat Chairman certified that attempts at amicable settlement were made but failed.
- Judge Afable dismissed the case on November 3, 1998, citing the expiration of the prescriptive period for filing the complaint as per Article 90 of the Revised Penal Code, which states that light offenses prescribe in two months.
- The judge argued that since the alleged offense occurred on February 15, 1998, and the complaint was filed after two months, it was already prescribed.
Administrative Complaint
- Mendova filed an administrative complaint against Judge Afable on July 7, 1999, claiming the judge's decision demonstrated ignoranc