G.R. No. 518 -MJ May 28, 1974
ELMER RAÑESES, complainant, vs. CELESTINO TOMINES, Former Municipal Judge of Coron, Palawan, respondent.

FACTS

The administrative complaint was filed by Elmer Rañeses against then Municipal Judge Celestino Tomines of Coron, Palawan, dated February 10, 1972. The core allegation was that Judge Tomines failed to act on an unlawful detainer complaint prepared by Rañeses on behalf of his parents-in-law. The respondent judge had reached compulsory retirement age and was retired on April 7, 1972, prior to the resolution of this case. The Supreme Court nevertheless ordered an investigation to proceed. The purpose was to guide the government in deciding on the respondent’s application for retirement benefits, as administrative liability could affect such entitlements.
The investigation revealed facts contrary to the complainant’s initial charges. The evidence demonstrated that Judge Tomines had indeed acted upon the complaint. He had examined the pleading and formed the belief that the action was not merely for unlawful detainer but实质上 for the recovery of ownership and possession of a parcel of land. Concluding that the case fell outside the jurisdiction of the municipal court, he forwarded the complaint to the Court of First Instance, which had proper jurisdiction. The respondent judge also informed the plaintiffs of this action.

ISSUE

Whether respondent Judge Celestino Tomines is administratively liable for neglect of duty in handling the complaint filed by Elmer Rañeses.

RULING

The Court dismissed the administrative complaint. The legal logic rests on the absence of any wrongful act or neglect of duty by the respondent judge. A judge’s determination of jurisdiction is a core judicial function. The evidence established that Judge Tomines did not ignore the complaint; he evaluated its substance. His conclusion that the action was for recovery of ownership, thereby exceeding his court’s jurisdiction, was a judicial assessment made in good faith. He then performed the correct procedural step by forwarding the case to the competent court and notifying the parties.
This finding was corroborated by the complainant’s own subsequent actions. After the investigation, Rañeses submitted a manifestation stating that the respondent’s acts were satisfactorily explained, expressing regret for an “honest mistake of facts,” and formally withdrawing his complaint. This voluntary desistance, while not determinative, strongly supported the conclusion that no administrative offense was committed. Since no malfeasance, misfeasance, or neglect was proven, and the judge acted within his authority in making a jurisdictional call, there was no basis for administrative sanction. His retirement did not extinguish potential liability, but the investigation found none to exist.