A.C. No. 288-J June 19, 1974
Gaudencio S. Urbina and Vedasto B. Gesmundo, complainants, vs. Judge Maximo A. Maceren, respondent.

FACTS

This administrative case originated from complaints filed against Judge Maximo A. Maceren. The Court initially dismissed the complaint on February 6, 1974, for failure to establish a prima facie case. Subsequently, the Court considered a belatedly reported “Joint Motion for Suspension and/or to Declare Respondent and Atty. Marcial Esguerra in Contempt of Court” filed by complainant Gaudencio S. Urbina. Urbina alleged that, through his former counsel, Atty. Marcial Esguerra, Judge Maceren made grave threats against his life to compel the withdrawal of the administrative complaints. The motion was supported by affidavits detailing alleged telephonic and personal threats. The Court also noted an indorsement from the Office of the President regarding an objection to the judge’s reappointment, which was referred to the respondent for comment.

ISSUE

The primary issue is whether the allegations of threats made by or on behalf of Judge Maceren to coerce the withdrawal of administrative complaints are substantiated, warranting further action against the respondent judge.

RULING

The Court denied complainant Urbina’s joint motion, finding the allegations of threats unsubstantiated. The ruling is anchored on several key points of legal logic. First, the Court evaluated the conflicting factual claims. Respondent Judge Maceren provided a categorical denial of making any threats, explaining that he merely requested Atty. Esguerra to inform Urbina that he bore no ill will and that an appeal was the proper recourse against his judicial decision. This denial was corroborated by a sworn affidavit from Atty. Esguerra, who explicitly denied making any threats as alleged by Urbina.
Second, the Court found the complainant’s charge inherently lacking in credibility based on the factual background. The initial administrative complaint had already been dismissed for failing to make a prima facie case. Furthermore, a related criminal complaint for “Knowingly Rendering an Unjust Judgment” filed by Urbina against the judge had been correctly dismissed by the provincial fiscal. The fiscal ruled that the question of whether the judgment was unjust was sub-judice as it was pending appeal, and there was no basis to conclude the judge knew it was unjust. The Court reasoned that, in light of these dismissals and ordinary human conduct, it would have been “extremely foolhardy and pointless” for the judge to engage in such threats, especially since another complainant, Atty. Gesmundo, would remain even if Urbina withdrew.
Finally, the Court used the resolution to issue a broader admonition. It reminded members of the bar that administrative complaints against judges must be filed with circumspection, without disrespectful language or offensive personalities. Lawyers owe fidelity to the courts, and filing unfounded charges to harass judges over unfavorable rulings, absent malice or gross ignorance, subjects them to disciplinary action. The Court reiterated the doctrine that judges are not administratively liable for mere errors of judgment. Accordingly, the motion was denied, and copies of the resolution were ordered sent to the Office of the President.