AM R 351 RTJ; (September, 1986) (Digest)
G.R. No. A.M. No. R-351-RTJ, A.M. No. R-359-RTJ, A.M. No. R-621-RTJ, A.M. No. R-684-RTJ, A.M. No. R-687-RTJ, A.M. No. 86-4-9987-RTC September 26, 1986
ABRAHAM L. RAMIREZ, LIWAYWAY B. SAMSON, VICTORIA TORRES, ESPERANZA LAZARO, and JESUS ALBA, complainants, vs. HON. ANTONIA CORPUZ-MACANDOG, Respondent.
FACTS
Respondent Judge Antonia Corpuz-Macandog of the RTC, Caloocan City, faced six consolidated administrative complaints. In A.M. No. R-351-RTJ, she ordered the arrest of Deputy Sheriff Abraham Ramirez for alleged contempt, enforcing a preliminary injunction she issued, despite a prior lawful demolition order from another judge. She effected the arrest via a handwritten note to a police general. In A.M. No. R-359-RTJ, she was accused of undue delay in resolving motions, with allegations of antedating an order to feign compliance. Other complaints involved issuing a writ of execution pending appeal without a bond, deciding a case without proper raffle and despite a challenge to her authority, and rendering a decision under alleged undue pressure from a litigant.
ISSUE
Whether respondent Judge Macandog is administratively liable for various acts constituting misconduct and conduct unbecoming of a judicial officer.
RULING
Yes, respondent is guilty of gross misconduct and is dismissed from service. The Court found her actions demonstrated a pattern of arbitrariness, abuse of authority, and disregard for judicial procedures. Her arrest of Sheriff Ramirez via a handwritten note, bypassing proper contempt proceedings, was a capricious use of power. Her delay in resolving motions and the suspicious circumstance of an antedated order showed neglect of duty. Issuing execution pending appeal without requiring a bond violated procedural rules and prejudiced a party’s right to appeal.
Most egregiously, in one case, she decided a matter despite a clear challenge to her authority as merely a pairing judge for limited purposes under internal court rules. Her hasty assumption of jurisdiction, ignoring a request to refer the jurisdictional question to the Supreme Court, constituted a blatant overreach and misconduct. Her defense that a prior authorization from the Court was revoked by the Judiciary Reorganization Act further showed a lack of understanding or willful disregard of applicable rules. Collectively, these acts revealed her mental and moral unfitness for judicial office, warranting dismissal with forfeiture of all benefits and disqualification from future government service.