AM 251 J; (October, 1974) (Digest)
A.M. No. 251-J. October 31, 1974. JOSE D. FIGUEROA, complainant, vs. NATALIO P. AMARGA, respondent.
FACTS
Complainant Jose D. Figueroa, an administrative officer, filed an administrative case against respondent Judge Natalio P. Amarga of the Court of First Instance of Samar, Branch IV. The complaint alleged five charges, including partiality, unjust practices, and violation of Republic Act No. 3019 . The core accusation was that the judge used Ruperto Galit as a tool to fabricate and file criminal cases for usury and qualified theft against Figueroa and his wife to harass them. This stemmed from a dispute where the Galits alleged that Mrs. Figueroa had improperly taken two of Mr. Galit’s salary checks to settle a loan they claimed was already paid.
The Supreme Court referred the matter to Associate Justice Ruperto G. Martin of the Court of Appeals for investigation. Justice Martin’s report detailed that the Galits had voluntarily approached Judge Amarga at his residence seeking help to recover their checks, after expressing futility in seeking redress from the school superintendent or the chief of police due to alleged connivance. With all provincial fiscals attending a seminar, the judge, upon their insistence, advised them to file a subscribed letter-complaint. He then conducted a preliminary investigation, found a prima facie case, and properly referred the records to the Provincial Fiscal for the filing of formal informations.
ISSUE
Whether respondent Judge Natalio P. Amarga is administratively liable for the charges of partiality, unjust practices, and harassment in connection with the criminal cases filed against the Figueroas.
RULING
The Court, adopting Justice Martin’s report, exonerated Judge Amarga and dismissed the complaint. The legal logic is that the evidence failed to substantiate any administrative misconduct. The judge’s actions were a proper response to citizens seeking judicial assistance under exigent circumstances—specifically, the absence of fiscals. His conduct of a preliminary investigation and subsequent referral to the fiscal’s office followed standard legal procedure and demonstrated no bias. The charges were found to be unsubstantiated and appeared to be a tactical maneuver by complainant Figueroa to disqualify the judge from presiding over the pending criminal cases against him and his wife.
Furthermore, the Court noted grave indications that perjury and subornation of perjury may have been committed in the filing of the administrative complaint and during the investigation, as the complainant’s and his witnesses’ testimonies were found incredible and inconsistent. Consequently, while dismissing the case against the judge, the Court ordered the records referred to the Secretary of Justice for a separate investigation into these potential criminal acts. This referral underscores the Court’s duty to protect judicial integrity from baseless attacks and to ensure that the processes of the Court are not abused for ulterior purposes.
