G.R. No. A.M. No. 1530-MJ May 30, 1978
NENITA CASTAÑETO, complainant, vs. HON. BUENAVENTURA S. NIDOY, Municipal Judge of Binalonan, Pangasinan, respondent.

FACTS

On February 10, 1977, Nenita Castañeto filed a letter-complaint against Municipal Judge Buenaventura S. Nidoy. She alleged that during the proceedings of an unlawful detainer case (Civil Case No. MC-B-3-30) where she was involved, the judge failed to keep proper records. She further claimed that the transcripts of stenographic notes were tampered with to delete portions prejudicial to the plaintiff and to insert conditions favorable to that party. A decision was rendered against her, and she requested a new trial to prevent a judgment based on this allegedly manipulated evidence.
In his comment dated March 8, 1977, Judge Nidoy denied all allegations. He asserted that a stenographer was present at every hearing and that the transcripts were duly prepared and forwarded to the Court of First Instance when the case was appealed. He maintained the decision was based solely on the evidence, not on bias, and noted that his judgment had been affirmed with modification on appeal. He prayed for the complaint’s dismissal.

ISSUE

Whether respondent Judge Buenaventura S. Nidoy is administratively liable for the alleged irregularities in handling the unlawful detainer case, specifically for not keeping records, tampering with transcripts, and displaying bias.

RULING

The Supreme Court dismissed the complaint for lack of merit. The legal logic proceeded from examining the substantive deficiencies in the complainant’s allegations. First, the claim that no records were kept was contradicted by the existence and transmittal of stenographic notes to the appellate court; the complainant herself admitted the transcripts existed when alleging their tampering. Second, the charge of transcript tampering was unsubstantiated. The proper remedy for any alleged inaccuracy was a judicial application for correction, which the complainant did not avail. Third, the imputation of bias and prejudice was purely conjectural, as no specific details were provided to support it. The Court found it significant that the decision was substantially affirmed on appeal, indicating the judgment’s integrity. Finally, the Court noted an ambiguity regarding the complainant’s legal personality and interest in the original detainer case, as she was not named as a party in the decisions. Consequently, the charges were deemed baseless and failed to establish any administrative misconduct on the part of the respondent judge.