Title
Supreme Court
Hon. Sharon Magayanes vs. Hon. Leah Angeli B. Vasquez-Abad
Case
A.M. No. MTJ-23-014 (Formerly JIB FPI No. 21-024-MTJ
Decision Date
Apr 11, 2024
Judge Abad dismissed cases *motu proprio* pre-raffle, violating rules; Judge Alamada falsified records. Both faced sanctions: Abad dismissed, Alamada disbarred; other complaints dismissed for lack of merit.

Case Summary (A.M. No. MTJ-23-014 [Formerly JIB FPI No. 21-024-MTJ)

Consolidated Cases

  • A.M. No. MTJ-23-014: Alamada vs. Abad (Gross Ignorance of Law)
  • A.M. No. MTJ-23-015: Abad vs. Alamada, Worwor-Miguel, De Jesus (Dishonesty, Misconduct)
  • A.M. No. MTJ-24-026: Abad & Sakkam vs. Alamada (Conduct Unbecoming)
  • A.M. No. MTJ-24-027: Alamada vs. Sakkam & Abad (Gross Ignorance, CJC Violation)

Key Dates

  • April 20–26, 2021: Filing, raffle and motu proprio dismissal of four criminal cases against Jeffrey Ostil Tamayo
  • June–October 2021: Exchange of administrative complaints and correspondence among judges
  • November 2020–July 2021: Continued salary deposits to Eraga’s LGU-issued cash card
  • March–June 2022 & September 2022–March 2023: OED and JIB Reports & Recommendations
  • April 11, 2024: En Banc decision

Applicable Law

  • 1987 Philippine Constitution
  • Rules of Court: Rule 114 (bail), Rule 140 (administrative procedure), Rules on Summary Procedure
  • Supreme Court and OCA Circulars: A.M. Nos. 03-8-02-SC, 05-08-26-SC; SCAC Nos. 33-2020, 89-2020, 94-2020; Circular 1-90
  • 2004 New Code of Judicial Conduct (NCJC)
  • 2023 Code of Professional Responsibility and Accountability (CPRA)
  • A.M. No. 21-08-09-SC (penalty guidelines for administrative offenses)

Factual Background

  1. MTJ-23-014 (Alamada vs. Abad)
    Abad, as Executive Judge, motu proprio dismissed three summary‐procedure criminal cases before raffle. Alamada charged her with gross ignorance, seeking preventive suspension. Abad argued good faith reliance on circulars and promptly recalled her orders once clarified.

  2. MTJ-23-015 (Abad vs. Alamada, Worwor-Miguel, De Jesus)
    Eraga claimed his LGU-issued cash card was retained by Alamada’s staff and that salary credits continued to be withdrawn after his September 2020 resignation. Abad accused Alamada and her staff of falsifying JO‐worker payroll registers and misappropriating public funds.

  3. MTJ-24-026 (Abad & Sakkam vs. Alamada)
    Abad and Sakkam alleged that Alamada made demeaning and discourteous comments during the videoconference raffle of cases, including references to vaccination status and threats concerning retirement.

  4. MTJ-24-027 (Alamada vs. Abad & Sakkam)
    Alamada counter‐accused Abad and Sakkam of gross ignorance and NCJC violations for filing unverified administrative complaints and for unauthorized notarizations under SC Circular 1-90.

Issue

Are the respondents administratively liable under the Constitution, Rules of Court, relevant circulars, NCJC and CPRA for:

  • Motu proprio dismissals (Abad)?
  • Falsifying payroll registers and misappropriating funds (Alamada, Worwor-Miguel, De Jesus)?
  • Improper conduct or unverified complaints (Abad, Sakkam)?

Court’s Analysis & Rulings

  1. MTJ-23-014 (Abad’s gross ignorance charge)

    • Abad misinterpreted summary‐procedure and Executive Judge directives amid COVID-19 circulars but immediately recalled her dismissal orders.
    • First administrative infraction; lack of malice or repetition.
      Ruling: Admonish Judge Abad for future compliance.
  2. MTJ-24-026 & MTJ-24-027 (Hostility and unverified complaints)

    • Notarization by Judge Sakkam and complaint investigation by Abad fall within their official functions (SC Circular 1-90; NCJC Canon 2).
    • Allegations of discourtesy and unverified letters lacked personal knowledge and credible evidence.
      Ruling: Dismiss complaints against Abad and Sakkam for lack of merit.
  3. MTJ-23-015 (Payroll falsification & fund misappropriation)

    • Alamada admitted signing eight JO payroll registers certifying Eraga’s service after his resignation.
    • ATM records and witness testimony (stenographer Agoncillo) show Alamada took Eraga’s cash card, directed withdrawals of LGU-credited funds, and misappropriated them.
    • Worwor-Miguel and De Jesus signed falsified registers at Alamada’s instruction without knowledge of Eraga’s separation.
      Findings:
      Falsification of Official Documents (payroll registers)
      Serious Dishonesty (misappropriation of public funds, degrading court integrity)
      Gross Misconduct (violating NCJC Canons 2 & 4)
      Commission of Crimes Involving Moral Turpitude (abuse of judicial authority for private gain)

Penalties

  • Judge Sharon M. Alamada
    • Dismissed from service; forfeiture of all benefits except accrued leave credits; disqualified from any public office
    • Disbarred; name stricken from the Roll

...continue reading

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.