A.M. No. 97-MJ. August 31, 1976.
FISCAL JUAN A. ABING, complainant, vs. JUDGE CLOTILDE J. SALAZAR, respondent.

FACTS

Acting Assistant Provincial Fiscal Juan A. Abing filed an administrative complaint seeking the disqualification of Municipal Judge Clotilde J. Salazar of Balangiga, Eastern Samar, from hearing a criminal case for Qualified Theft. The complaint alleged four irregularities: (1) administering oaths of office to two officials without requiring their signatures; (2) issuing a summons in a forcible entry case after an excessive delay of over one year; (3) hearing and deciding a criminal case for Acts of Lasciviousness which was beyond her court’s jurisdiction due to the penalty; and (4) refusing to accept a criminal complaint for Slander by Deed against a parish priest on a flimsy pretext, causing inconvenience to the complainant.
The case was referred to the Supreme Court and subsequently to an investigating District Judge. The investigation revealed that for Charge No. 1, the unsigned oaths were due to oversight and excitement during the ceremonies, with one later corrected. For Charge No. 2, the delay in summons issuance was attributed to the parties’ own request to explore amicable settlement, given their familial relationship and concurrent criminal proceedings. For Charge No. 4, the evidence showed the complainant ultimately filed and later withdrew the slander case, with no proof of improper refusal by the judge.

ISSUE

Whether respondent Judge Clotilde J. Salazar should be held administratively liable for the alleged irregularities in her judicial conduct.

RULING

The Supreme Court dismissed the charges but admonished the respondent to exercise more caution. The legal logic is grounded on the distinction between mere error and administrative culpability. Charges Nos. 1, 2, and 4 were found unsubstantiated. The procedural lapses in administering oaths and the delayed summons were excusable under the specific circumstances—oversight and a bona fide attempt to facilitate settlement, respectively. The refusal to accept a complaint was not proven, as the private complainant ultimately filed and withdrew it.
However, Charge No. 3 was admitted: the respondent erroneously assumed jurisdiction over a criminal case beyond her authority. The Court ruled this was an honest mistake of judgment, not prompted by improper motive or a desire to commit injustice. While such a jurisdictional error is serious, absent proof of bad faith, gross ignorance, or malicious intent, it does not warrant administrative sanction. Nevertheless, the Court emphasized that judges must exhibit circumspection, prudence, and wise discretion to maintain public faith in judicial institutions. The dismissal with admonition serves to correct the lapse without imposing punitive measures, balancing the need for judicial accountability with the recognition of human error in good faith.