G.R. No. MTJ-00-1259; August 4, 2000
Alfonso C. Ortiz, complainant, vs. Judge Alex L. Quiroz, respondent.

FACTS

Complainant Alfonso Ortiz filed criminal cases for malicious mischief and grave threats against Inocencio Hernando. The cases, falling under the Revised Rule on Summary Procedure due to the imposable penalties, were raffled to respondent Judge Alex L. Quiroz. Initially, the judge ordered the prosecution to explain the absence of a barangay certification. However, he later issued an order stating the cases fell under exceptions to conciliation and would be tried under ordinary procedure, amending his prior order.
During trial under ordinary procedure, complainant testified but the prosecution failed to formally offer his testimony as evidence. Respondent judge consequently ruled the testimony inadmissible. After the prosecution presented other evidence and the defense filed a demurrer, the judge denied the demurrer, considered the cases submitted, and eventually rendered a decision acquitting the accused. Complainant then filed this administrative case, alleging gross ignorance of the law for not applying summary procedure, which crippled his case.

ISSUE

Whether respondent Judge Alex L. Quiroz is administratively liable for gross ignorance of the law for applying the ordinary rules of procedure instead of the mandatory Revised Rule on Summary Procedure.

RULING

Yes, respondent judge is administratively liable. The Court found that the criminal charges for grave threats and malicious mischief, where the alleged damage was P50,000, clearly fell within the scope of the Revised Rule on Summary Procedure, which applies to cases with penalties not exceeding six months imprisonment or a P1,000 fine. Respondent judge therefore committed a serious error in ordering the trial under ordinary rules. This error was not merely judicial but a disregard of basic procedural rules that judges are mandated to know proficiently.
The Court, however, found insufficient evidence to support the charge of knowingly rendering an unjust judgment, as bad faith or malicious motive was not proven. The evaluation of evidence and the acquittal, by themselves, do not establish an unjust judgment. Nonetheless, a judge’s duty to maintain professional competence includes a mastery of fundamental procedural rules. His failure to apply the correct procedure constituted gross ignorance of the law. Accordingly, the Court reprimanded Judge Quiroz with a stern warning.