G.R. No. A.M. No. 32-MJ & 33-MJ July 18, 1975
LEON FRANADA, ET AL. and VERONICA P. ULSA, complainants, vs. MUN. JUDGE VICENTE M. OBLENA, JR., respondent.

FACTS

In Administrative Matter No. 32-MJ, Judge Vicente M. Oblena, Jr. was charged via telegram-complaint for alleged connivance in illegal logging operations. The supposed complainants, however, disowned any knowledge or participation in sending the telegram during the investigation conducted by Judge Ernesto P. Valencia. One named complainant could not be located. No evidence was presented to substantiate the charges. Judge Valencia recommended dismissal for lack of evidence.
In Administrative Matter No. 33-MJ, complainant Veronica P. Ulsa alleged that Judge Oblena used his authority to frighten her laborers and prevent them from entering her licensed logging area. During the preliminary inquiry, the complainant moved to withdraw the complaint, admitting her allegations were based on hearsay from her laborers and filed out of anger. She testified the respondent had secured a Certificate of Private Woodland Registration for his titled land but had not actually engaged in logging business or removed any logs.

ISSUE

The primary issue is whether Judge Oblena incurred administrative liability for securing a private woodland registration certificate without prior judicial permission and for the alleged acts complained of.

RULING

The Supreme Court dismissed both complaints. For A.M. No. 32-MJ, the burden of proof rests on the complainant, and the complete failure to present any substantiating evidence warranted dismissal. For A.M. No. 33-MJ, the Court held the respondent incurred no administrative liability. Firstly, under Section 1829 of the Revised Administrative Code, a private owner of land containing timber has a duty to register his title with the Director of Forestry. This legal obligation of a landowner is distinct from his judicial office and required no prior permission from a District Judge. Secondly, there was no violation of Canons 24 and 25 of the Canons of Judicial Ethics. Canon 24 prohibits using office prestige for private business, but the act of mere registration is not engaging in business. Canon 25 warns against investments apt to be involved in litigation, but the complainant admitted the respondent had not actually taken logs or operated a business. Logging business implies continuity of acts, which was absent. The respondent’s compliance with a statutory duty for his private property, without actual commercial operation, did not constitute an ethical breach or render him unfit for office.