A.M. No. 91-MJ and No. 319-MJ July 23, 1974
ANTONIO ABIBUAG, complainant, vs. MUNICIPAL JUDGE SEVERINO B. ESTONINA OF CALAPE, BOHOL, respondent.

FACTS

In Administrative Case No. 91-MJ, complainant Antonio Abibuag charged respondent Municipal Judge Severino Estonina with grave misconduct. Abibuag alleged that on November 7, 1970, while he was detained, Judge Estonina summoned him and attempted to induce him to dissolve the local chapter of the Federation of Free Farmers and to desist from asserting rights under agrarian reform laws, threatening him with more charges if he refused. The judge allegedly stated the Land Reform Code was not applicable in Bohol. Respondent judge denied all allegations, characterizing the complaint as a vengeful harassment.
The administrative case was set for investigation. The complainant and his counsel failed to appear, requesting postponement. Respondent judge objected, informing the investigator that the incident was the same subject of two prior criminal cases (Criminal Cases Nos. 196 and 197) filed against him for alleged violations of the Agricultural Land Reform Code ( R.A. No. 3844 ). In those criminal cases, after a preliminary investigation, Judge Antonio Beldia of the CFI had issued an order dated November 27, 1970, finding no crime committed and no reasonable ground to proceed, thereby exonerating respondent. The investigator in the administrative case, considering the exoneration in the criminal cases and the complainant’s non-appearance, dismissed the administrative complaint.

ISSUE

Whether respondent Municipal Judge Severino Estonina should be held administratively liable for the alleged acts of misconduct and ignorance of the law.

RULING

The Court dismissed the administrative complaint for lack of merit. The ruling is anchored on the findings from the preliminary investigation in the related criminal cases. Judge Antonio Beldia meticulously evaluated the evidence, particularly complainant Abibuag’s testimony, and concluded that respondent judge’s actions did not constitute a violation of the cited provisions of R.A. No. 3844 . The testimony revealed that respondent merely informed the complainant of the charge against him and called the farmers’ group “troublesome,” likely due to their demand for a 70-30 crop sharing arrangement which lacked a legal basis in Bohol at the time, as the land reform law had not been extended to Calape. This remark, without accompanying acts of interference, did not violate the law.
Furthermore, Judge Beldia correctly ruled that the applicability of the Agricultural Land Reform Code was contingent upon a prior proclamation of an area as a land reform zone, a condition not met in Calape, Bohol, at the time of the incident. Therefore, respondent judge’s statement regarding the law’s inapplicability, while perhaps imprudent, was substantively accurate and not demonstrative of ignorance. The Court found the dismissal of the administrative case by the investigator proper, as it would be inappropriate to administratively sanction a judge for acts already judicially scrutinized and found to constitute no criminal offense. The charges were deemed unsubstantiated.