A.M. No. 480-MJ. March 22, 1977. FELICIDAD GUERRA VDA. DE LAPEÑA, complainant, vs. MUNICIPAL JUDGE JOSE L. COLLADO, respondent.
FACTS
Complainant Felicidad Guerra Vda. de Lapeña charged Municipal Judge Jose L. Collado of Bautista, Pangasinan, with falsification of public documents. The charge stemmed from two Certificates of Service dated July 2 and August 1, 1973, wherein respondent judge certified that all petitions and motions submitted for determination for ninety days or more had been resolved, enabling him to collect his salary. The complainant alleged this certification was false, as the judge had not resolved her pending petitions for preliminary injunction in two forcible entry cases (Civil Cases Nos. 382 and 383) and related motions to deposit harvested crops.
Respondent judge denied falsification. He claimed the injunction petitions were denied orally in open court, and the resolution on the deposit motions was deferred pending a determination on whether the defendants were squatters. He further argued that as his court was not yet a court of record, no written orders were required. The case was referred to an investigating District Judge for inquiry.
ISSUE
Whether respondent Municipal Judge Jose L. Collado is administratively liable for falsifying his Certificates of Service dated July 2 and August 1, 1973.
RULING
The Supreme Court exonerated Judge Collado of the charges but admonished him to act with due care. The legal logic centered on analyzing the truthfulness of each certification against the procedural timeline. For Civil Case No. 383, the ninety-day period for resolving the injunction petition had not yet lapsed by the certification dates, so no falsification occurred. For Civil Case No. 382, however, the investigation found that the petition was deemed submitted by April 3, 1973, making the ninety-day deadline July 2, 1973. Therefore, the August 1 certification stating all such matters were resolved was false, as the injunction petition remained undetermined.
The Court rejected the judge’s defense that his court was not a court of record, noting evidence that it was and had an official stenographer. However, the Court found the single false statement was not due to malice or bad faith but to carelessness, negligence, or undue reliance on a subordinate. Applying the standard from Secretary of Justice v. Bullecer, such an act, while constituting inefficiency, did not rise to the level of serious misconduct warranting severe penalty in the surrounding factual context. The exoneration with an admonition balanced the need for judicial accountability with the absence of corrupt intent, emphasizing the imperative for judges to exercise utmost diligence in administrative certifications to maintain public trust in the prompt administration of justice.
