A.M. No. 1255-CTJ August 6, 1980
Esteban Ubongen, complainant, vs. City Judge Toribio S. Mayo of Baguio, respondent.

FACTS

In Criminal Case No. 30665, Paulino Lopez and two others were charged with falsifying the signature of Francisca Ubungen in a 1969 “Agreement” and using that document after her death to transfer her rights over a Baguio lot to Lopez, to the damage of her heirs. After trial, respondent Judge Mayo acquitted all accused on the ground of reasonable doubt. The decision, dated September 23, 1975, acknowledged a variance between the signature on the agreement and Francisca’s voter’s ID, but held the prosecution failed to prove which accused made the falsified signature, relying merely on suspicion.
Complainant Esteban Ubungen, Francisca’s father, filed a verified complaint on April 27, 1976, charging the judge with rendering an unjust decision for failing to apply the legal presumption that the holder/user of a falsified document is presumed to be the falsifier. In his answer, respondent judge claimed he “seriously doubted” whether the signature was falsified at all, a statement the Supreme Court found inaccurate, as his decision clearly found the document falsified but doubted the accused’s authorship. The Court noted this as a distortion and an attempt to mislead. Respondent also admitted he was unaware of the pertinent legal presumption, pleading his error was one of judgment made without malice.

ISSUE

Whether respondent Judge Toribio S. Mayo is administratively liable for gross ignorance of the law and for attempting to mislead the Supreme Court in his defense.

RULING

Yes, respondent judge is administratively liable. The Supreme Court found his failure to apply a basic legal principle constituted gross ignorance of the law. The established rule, as cited in People vs. Caragao, is that where an accused is shown beyond doubt to have used a forged document, it is presumed he is its forger. The information specifically alleged Lopez used the falsified document, and the trial evidence included testimony that Lopez presented it to the assessor’s office. Even if the judge doubted Lopez was the forger, he should have known that the use of a falsified document by a private person is itself a crime under Article 172 of the Revised Penal Code, which was alleged in the information and proven.
The Court emphasized that while judges are not infallible and mere errors of judgment do not ordinarily warrant discipline, they are required to be conversant with basic legal principles. A judge’s failure to exhibit even a cursory acquaintance with well-settled doctrines, especially in inferior courts, is impermissible. Furthermore, the respondent’s inaccurate statement in his answer, which misrepresented the tenor of his own decision, was a separate censurable act of attempting to mislead the Court. Accordingly, respondent Judge Mayo was ADMONISHED to exercise more prudence and circumspection and REPRIMANDED for attempting to mislead the Supreme Court. A copy of the decision was ordered attached to his personal record.