A.M. No. 981-CFI. July 29, 1977.
GIL GEÑORGA, complainant, vs. HON. PEDRO C. QUITAIN, District Judge of the Court of First Instance of Masbate, Branch II, respondent.

FACTS

Complainant Dr. Gil Geñorga, a government medico-legal officer, was subpoenaed to testify in a murder case before respondent Judge Pedro C. Quitain. Prior to the scheduled hearing, Geñorga sent a telegram to the judge inquiring about the reimbursement of his traveling expenses. Having received no reply, he did not appear in court. Consequently, upon the prosecution’s motion, Judge Quitain issued a warrant for Geñorga’s arrest for his failure to obey the subpoena. Geñorga was arrested and detained for several days before being allowed to travel to Masbate at his own expense to testify.
After testifying and being released, Geñorga attempted to explain his absence to the judge in chambers. He alleged that Judge Quitain ignored him and treated him with discourtesy during this meeting. Based on these events, Geñorga filed an administrative complaint against Judge Quitain for grave abuse of authority and conduct unbecoming a judge.

ISSUE

Whether respondent Judge Pedro C. Quitain committed grave abuse of authority and conduct unbecoming a judge warranting administrative sanction.

RULING

The Supreme Court dismissed the administrative complaint for lack of merit. On the charge of grave abuse of authority, the Court found the issuance of the warrant of arrest to be a valid exercise of judicial discretion. Citing People v. Montejo, the Court emphasized the inherent power of a court to compel the attendance of witnesses in criminal cases. A subpoena duly served creates a legal obligation to appear. The judge was not duty-bound to reply to Geñorga’s telegram, which was framed more as a demand than a request. The failure to appear justified the coercive measure to ensure the administration of justice, and the judge’s action was within his authority to prevent the prosecution from being handicapped.
Regarding the charge of conduct unbecoming a judge, the Court found the accusation unsubstantiated. Judge Quitain explained that he heard Geñorga’s explanation courteously in chambers and subsequently issued an order for his release, which contradicted the claim of being ignored. The Court, referencing Bartolome v. De Borja, noted that while judges must maintain decorum, not every lapse in equanimity or courtesy merits disciplinary action, especially given the pressures of judicial office. Furthermore, the complainant’s failure to file a reply to the judge’s detailed comment on the charges suggested an acceptance of the explanation. Therefore, no administrative liability attaches to the respondent judge.