G.R. No. A.M. No. 502-MJ June 30, 1977
SALVADOR VELOSO, complainant, vs. MUNICIPAL JUDGE GODOFREDO CARMONA of Socorro, Oriental Mindoro, respondent.

FACTS

Marceliano Rivera, Jr. was charged with slight physical injuries in the municipal court of Pola, Oriental Mindoro, with Salvador Veloso as the offended party. Rivera voluntarily surrendered and posted a character bond. Godofredo L. Carmona, the municipal judge of Socorro acting as judge for Pola, presided. At the initial hearing on August 18, 1973, Rivera did not appear, leading to the cancellation of his bond. The hearing was reset for August 28, 1973. Judge Carmona claimed Veloso was notified of the new date through his father and a letter.
On August 28, Rivera appeared with counsel de oficio, but Veloso was absent. The chief of police requested a postponement, but Rivera’s counsel objected. The court proceeded with Rivera’s arraignment, where he pleaded guilty. When Veloso arrived later that morning, he was informed the case was already terminated. Judge Carmona promptly signed a decision convicting Rivera, imposing a fine of twenty-five pesos and public censure, “without costs,” and appreciating the mitigating circumstances of plea of guilt and voluntary surrender. No civil liability was adjudged, and Rivera paid the fine that same day.

ISSUE

Whether Municipal Judge Godofredo Carmona should be held administratively liable for his handling of Criminal Case No. 2584, particularly concerning the proceedings, the imposition of penalty without civil liability, and the treatment of the complainant.

RULING

The Supreme Court dismissed the administrative complaint but issued a warning and admonition to Judge Carmona. The Court found that the factual circumstances did not warrant disciplinary action, yet identified significant procedural lapses requiring correction. Legally, while a judge has discretion in conducting trials, such discretion must be exercised with due care to uphold judicial integrity and fairness.
The Court noted the Judicial Consultant’s observations that respondent judge should have ordered the arrest of the accused after his failure to appear at the initial hearing despite notice to his bondsmen. More critically, the judge erred in not making a finding on the civil liability of the accused. The complaint explicitly alleged physical injuries requiring medical treatment, thus necessitating an adjudication on civil indemnity under the rules governing criminal procedure where the offense resulted in damages. The Court clarified that Veloso’s grievance about not receiving a copy of the decision was mitigated because the chief of police, as prosecution representative, was furnished a copy.
The legal logic centers on the balance between judicial discretion and mandatory procedural duties. The dismissal of the complaint indicates that the judge’s actions, while flawed, did not rise to the level of gross ignorance of the law or bad faith warranting sanctions. However, the warning underscores that judges must meticulously follow procedural rules, especially concerning the arrest of absent accused and the mandatory award of civil liability arising from the crime, to prevent any suspicion of partiality or negligence. The resolution attaches a copy to Judge Carmona’s record to note the admonition for future conduct.