A.M. No. 532-MJ. July 25, 1975.
PAULA S. QUIZON, ET AL., complainants, vs. JUDGE JOSE G. BALTAZAR, JR., respondent.

FACTS

Complainants, teachers and officers of a Parent-Teachers Association, wrote a letter in October 1972 to the Department of Public Information complaining of alleged abuses by barrio officials. In response, the Barrio Captain filed a libel complaint against them, docketed as Criminal Case No. 2368 in the Municipal Court of Mabalacat, Pampanga, presided by respondent Judge Jose G. Baltazar, Jr. During the preliminary investigation set for December 4, 1972, complainants requested a postponement due to their counsel’s absence. Respondent judge denied the motion and proceeded with the investigation without defense counsel, concluding it in less than an hour. The next day, he issued a warrant of arrest, which was served at nighttime.
After the arrest, a relative of one complainant approached the judge at his home to request a reduction of the bail bond, which had been set at P1,000. The judge deferred action until the next morning, reducing the bail to P300 only after complainants had spent the night in jail. Complainants charged the judge with grave ignorance of the law for taking cognizance of a libel case, arguing jurisdiction lies exclusively with the Court of First Instance under Republic Act No. 4363 . They also alleged partiality, claiming the barrio officials were political followers of a mayor closely identified with the respondent.

ISSUE

Whether respondent Judge Jose G. Baltazar, Jr. is administratively liable for grave ignorance of the law and for procedural violations in handling the libel case.

RULING

Yes, the respondent judge is administratively liable. The Supreme Court found him guilty of grave ignorance of the law. Republic Act No. 4363 , which amended Article 360 of the Revised Penal Code, is clear and categorical: a complaint or information for libel may be filed only in the Court of First Instance. Preliminary investigation for such a case may be conducted only by the city court of the city or the municipal court of the capital of the province. The Municipal Court of Mabalacat is neither, rendering the respondent utterly without jurisdiction. A Department of Justice circular dated April 5, 1967, had already disseminated this information to all judges, leaving no excuse for the error.
Beyond jurisdictional ignorance, the Court noted several injudicious acts. The letter-complaint was a privileged communication, lacking specific names, which should have prompted caution. Denying a first-time postponement request from unrepresented accused, who were mostly teachers, demonstrated undue haste. Conducting and concluding a preliminary investigation in under an hour without reducing the examination to writing violated Section 87 of the Judiciary Act. Furthermore, delaying the bail reduction petition, ensuring complainants spent a night in jail, suggested the judge allowed himself to become a tool for harassment. However, the charge of partiality was not sufficiently proven. Consequently, the Court suspended Judge Baltazar for six months without pay for grave ignorance of procedural and substantive law.