Case Summary (A.M. No. RTJ-92-876)
Original Supreme Court Ruling
In its September 19, 1994 per curiam decision, the Court held that Judge Muro’s motu proprio dismissal amounted to gross ignorance of the law and a denial of the prosecution’s constitutional right to due process. It ordered his dismissal from the service with cancellation of eligibility, forfeiture of leave credits and retirement benefits, and disqualification from re-employment.
Proceedings on Reconsideration
Judge Muro filed a motion for reconsideration. The State Prosecutors opposed it, and the Regional Trial Court Judges Association and MABINI sought to intervene as amicus curiae, but both petitions were denied. In his pleadings, Judge Muro denied bad faith, pointed to his valedictorian honors and bar ranking, and characterized his action as a legal error correctable by appeal.
Court’s Reaffirmation of Misconduct
The Court reiterated that while simple legal errors are remediable by appeal, egregious errors that deprive parties of fundamental rights—here, the prosecution’s right to be heard—constitute judicial misconduct. Judge Muro’s summary dismissal without notice or comment demonstrated partiality, bad faith, and abuse of discretion in violation of due process and judicial ethics.
Consideration of Mitigating Circumstances
Upon reconsideration, the Court acknowledged Judge Muro’s previously unblemished record, his contrition, and his “solemn commitment” to adhere strictly to judicial canons. The State Prosecutors, in their later filings, likewise left penalty modification to the Court’s discretion. These factors justified commutation of the original penalty.
Legal Principles Emphasized
The Court underscored that speed is not the paramount objective of a trial, that judges must hear both sides with patience and impartiality, and that judicial discretion
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Citation and Parties
- G.R. No. RTJ-92-876; 321 Phil. 474 (1995), En Banc
- Complainants: State Prosecutors of the Department of Justice
- Respondent: Judge Manuel T. Muro
Background and Procedural History
- Respondent judge motu proprio dismissed eleven criminal cases against Mrs. Imelda Marcos for alleged violation of Central Bank foreign exchange restrictions
- Dismissal based solely on newspaper reports announcing lifting of all foreign exchange restrictions—characterized as “hearsay evidence, twice removed,” lacking admissibility and probative value
- No motion to quash filed by the defense and no opportunity afforded the prosecution to be heard before dismissal
- September 19, 1994 Decision: Court found gross ignorance of the law, ordered respondent’s dismissal from service, cancellation of eligibility, forfeiture of leave credits and retirement benefits, and disqualification from government re-employment
- Respondent filed a Motion for Reconsideration; complainants filed a Comment; respondent filed a Reply; complainants filed a Rejoinder
Attempts at Amicus Curiae Intervention
- Regional Trial Court Judges Association of Manila, Inc. and Movement of Attorneys for Brotherhood, Integrity and Nationalism, Inc. (MABINI) sought leave to intervene as amici curiae
- Both petitions for leave to intervene were denied by the Court on October 18, 1994 and November 8, 1994
Respondent’s Defense and Arguments
- Denied bad faith or corrupt intent in dismissing the cases
- Emphasized impeccable academic credentials: law school magna cum laude, class valedictorian, placed sixth in the Bar examination
- Argued that dismissal was an honest legal error remediable by appeal or other court remedies, not by administrative discipline
Court’s Analysis of Judicial Misconduct
- A single legal error, if egregious or motivated by bad faith or part of a pat