A.M. No. 1810-CTJ and A.M. No. 1995-CTJ. June 29, 1979.
Angelina S. Salcedo and Samuel C. Occeña, complainants, vs. Judge Enrique B. Inting, respondent.

FACTS

In Administrative Matter No. 1810-CTJ, complainant Angelina S. Salcedo charged respondent City Judge Enrique B. Inting with two counts. First, she alleged that from 1964 to 1974, the judge collected salary overpayments totaling P38,100.00, constituting violations of the Anti-Graft and Corrupt Practices Act and the Revised Penal Code. Second, she accused him of falsifying three applications for leave of absence in 1977 by stating he had no pending administrative case, when in fact Administrative Matter No. 1229-CTJ was pending against him. The respondent judge, in his comment, submitted a resolution from the City Fiscal of Davao dismissing the criminal charges for insufficiency of evidence and argued he was singled out among many judges who received similar overpayments.
In Administrative Matter No. 1995-CTJ, complainant Atty. Samuel C. Occeña charged the respondent judge with serious misconduct and conduct prejudicial to the judiciary. The allegations stemmed from the judge’s actions as a private citizen: first, for issuing a statement to a newspaper criticizing the complainant’s professional conduct, and second, for allegedly disrupting a Parents-Teachers Association meeting where the complainant was speaking. The respondent judge denied the charges, asserting his statements were privileged and his conduct at the meeting was proper, supported by affidavits from other attendees.

ISSUE

The central issue is whether the charges against Judge Inting in both administrative cases constitute sufficient grounds for disciplinary action.

RULING

The Supreme Court dismissed both administrative complaints for lack of merit. Regarding the salary overpayments, the Court found no administrative liability. The overpayments resulted from a statutory construction error by financial officers of the Department of Justice before judicial supervision was transferred to the Supreme Court. The respondent did not intervene in issuing the treasury warrants and received the amounts under an honest belief they were legally due. The City Fiscal’s resolution absolving him of criminal liability, due to the absence of malice or corrupt intent, was upheld. Administrative cases, being quasi-criminal, require proof beyond reasonable doubt, which was not met.
Concerning the leave applications, the Court found the respondent did not make the false statement. The notation “PENDING ADM. CASE, ‘NONE'” was stamped by Supreme Court employees, not written by the judge. Furthermore, even if he had applied for leave knowing of a pending case, a subsequent Court Memorandum Circular expressly permitted such leaves, upholding the presumption of innocence.
For the charges in the second case, the Court ruled that the alleged misconduct had no direct relation to the judge’s official duties. His published statement was a privileged critique of a lawyer’s public conduct, and the meeting disruption was not substantiated by evidence, being contradicted by affidavits. To warrant disciplinary action, a judge’s misfeasance must be directly connected to official duties, amounting to maladministration or willful neglect. The complained acts pertained to his private character and not his judicial functions. Therefore, no administrative sanction was justified.