A.M. No. MTJ-00-1262. April 6, 2000.
RODOLFO M. TAPIRU, complainant, vs. JUDGE PINERA A. BIDEN, respondent.

FACTS

Complainant Rodolfo Tapiru charged Judge Pinera Biden, Presiding Judge of the 6th Municipal Trial Court of Kabugao, Apayao, with arbitrary detention, grave misconduct, and grave abuse of authority. The complaint stemmed from the judge’s issuance of a protective custody order for Tapiru’s son, Richard, on October 10, 1996, based on a police request during a murder investigation, even before any formal criminal case was filed. Complainant alleged his son was actually arrested without a warrant two days earlier and detained until year-end. Additional charges included that the judge pressured the Tapirus to settle a separate “Alarms and Scandals” case through letters, improperly prevented the arrest of his own son, Hatcher Biden, in an attempted murder case, and conducted adoption proceedings without jurisdiction.
Judge Biden denied the charges. He explained the protective custody order was properly issued on October 10, 1996, to safeguard Richard Tapiru, whom he described as an “incorrigible criminal.” He admitted writing the settlement letters but claimed it was upon the parties’ plea for time. Regarding his son, he denied protection, attributing the arrest delay to the accused being away for studies. He argued the adoption case in 1984 was within municipal court jurisdiction at the time.

ISSUE

Whether respondent Judge Pinera A. Biden is administratively liable for the acts complained of.

RULING

Yes, the Supreme Court found Judge Biden administratively liable, though not for all charges. The investigating judge correctly refrained from ruling on the arbitrary detention charge to avoid prejudicing pending criminal cases. However, the Court found the judge committed impropriety and ignorance of the law. His act of writing letters to pressure a settlement in the “Alarms and Scandals” case was “unprocedural”; the proper course was to hear and decide the case on the merits. His conduct regarding his son’s case, while not conclusively proving coddling, failed to uphold the standard that a judge must avoid any appearance of impropriety or misuse of office for personal interest. Furthermore, his claim that municipal courts had jurisdiction over adoption in 1984 demonstrated gross ignorance of the law, as such jurisdiction was vested in juvenile and domestic relations courts or courts of first instance since 1975. A judge must be proficient in law and maintain conduct beyond reproach. Consequently, Judge Biden was found guilty of simple impropriety, simple misconduct, and gross ignorance of the law. He was reprimanded, fined Three Thousand Pesos (P3,000.00), and sternly warned.