AM MTJ 04 1542; (March, 2006) (Digest)
G.R. No. A.M. No. MTJ-04-1542. March 30, 2006. ATTY. VICENTE B. DE ASIS, Complainant, vs. JUDGE ARTURO G. DORONILA, Presiding Judge of the Municipal Circuit Trial Court of Jordan-Buenavista-Nueva Valencia, Guimaras, Respondent.
FACTS
On September 3, 2002, the Supreme Court issued Administrative Order No. 128-2002 designating Judge Ronaldo P. Melliza, Jr. as Assisting Judge of the MCTC of Jordan-Buenavista-Nueva Valencia, Guimaras. The order explicitly directed Judge Melliza to try and decide newly filed cases in that court, while respondent Judge Arturo G. Doronila was to continue trying and deciding only pending cases, including those submitted for decision. On February 7, 2003, a criminal case for Arson was filed against complainant Atty. Vicente B. De Asis before the said MCTC. Despite the administrative order, respondent Judge Doronila conducted the preliminary investigation and issued a warrant of arrest against De Asis.
In his defense, Judge Doronila argued that he acted on the new case because Judge Melliza, the designated assisting judge, was reportedly unable to perform his duties and no substitute had yet been appointed. He claimed he would face administrative complaints for inaction if he did not handle the new filings. The complainant countered that there was no immediate necessity for the respondent judge to act, and that his actions constituted a violation of the Supreme Court’s directive.
ISSUE
Whether respondent Judge Arturo G. Doronila is administratively liable for handling a newly filed criminal case and issuing a warrant of arrest, in violation of Supreme Court Administrative Order No. 128-2002.
RULING
Yes, respondent Judge Doronila is administratively liable. The Supreme Court affirmed the recommendation of the Office of the Court Administrator. The legal logic is straightforward: Administrative Order No. 128-2002 was a clear and lawful directive from the Supreme Court. It specifically allocated jurisdiction, mandating that Judge Melliza handle newly filed cases, while Judge Doronila was restricted to pending cases. The criminal case against De Asis was newly filed; therefore, it fell exclusively under Judge Melliza’s authority. Respondent judge’s awareness of the order and his subsequent defiance of it constituted a willful violation.
The Court rejected his justifications. The alleged unavailability of Judge Melliza did not automatically revoke or nullify the Supreme Court’s order. The proper course of action was for Judge Doronila to refer the matter to his executive judge for appropriate instruction, not to unilaterally assume jurisdiction. By disregarding a direct circular from the Supreme Court, Judge Doronila committed a less serious charge under Rule 140 of the Rules of Court, defined as violation of Supreme Court rules, directives, and circulars. Such willful non-compliance demonstrates disrespect for the Court’s authority and undermines judicial discipline. Accordingly, he was fined Fifteen Thousand Pesos (P15,000) with a stern warning.
