A.M. No. 2252-CFI EN BANC Adm. Case No. 2252-CFI January 18, 1982
RUFINO IGNACIO, complainant, vs. HON. MANUEL E. VALENZUELA, Presiding Judge, Court of First Instance of Rizal, Branch XXIX, Pasay City, respondent.

FACTS

Complainant Rufino Ignacio charged respondent Judge Manuel Valenzuela with serious misconduct for taking undue personal interest in a case. The charge stemmed from Civil Case No. 7159-P, where Ignacio was a plaintiff. The Executive Judge initially issued a temporary restraining order (TRO) on May 2, 1979. The case was later raffled to respondent’s branch. The defendants filed a motion to quash the TRO, which the plaintiffs opposed. Respondent Judge, who was officially on vacation leave from May 1 to 31, 1979, heard this motion in his chambers on May 8, 1979, and granted it the following day. Ignacio challenged the order’s legality before the Court of Appeals, which upheld the judge’s authority, citing de facto officer principles.
During the administrative investigation, evidence revealed that for the period May 2-9, 1979, the branch’s calendar of cases bore notations like “No hearing, Judge on vacation” for 70 other scheduled cases. Civil Case No. 7159-P was the sole exception, marked for hearing. The respondent claimed he had not received formal notice of his leave approval by May 8, though Supreme Court records showed notification was mailed on April 20, 1979.

ISSUE

Whether respondent Judge Manuel Valenzuela is administratively liable for his actions concerning Civil Case No. 7159-P.

RULING

Yes, the respondent is administratively liable for impropriety, though not for serious misconduct with corrupt motive. The Court of Appeals had already resolved the legality of his order quashing the TRO, finding he acted with at least de facto authority. However, administrative liability focuses on propriety beyond mere legality. The investigative report established impropriety by demonstrating the respondent singled out this specific case for action while on leave. The certified calendar showed his branch conducted no hearings on any other cases during that period, with all others marked as cancelled due to his vacation. His explanation—that he had not received leave approval and that courts often hear only a few calendared cases—was insufficient. The pattern indicated a selective departure from standard practice, creating an appearance of partiality and undue interest. This conduct erodes public confidence in judicial impartiality. While the evidence did not prove corrupt intent, the impropriety warranted sanction. The Court adopted the investigator’s recommendation, imposing a fine equivalent to one month’s salary and issuing a stern warning.