AM MTJ 01 1348; (November, 2004) (Digest)
A.M. No. MTJ-01-1348, MTJ-01-1352, MTJ-01-1358, and 01-2-100-RTC ; November 11, 2004
JUDGE DOLORES L. ESPAĂ‘OL, et al., complainants, vs. JUDGE LORINDA T. MUPAS, respondent. and RE: REPORT ON THE JUDICIAL AUDIT ON SEARCH WARRANTS AT THE RTC, DASMARIĂ‘AS, CAVITE, BRANCH 90.
FACTS
These consolidated administrative cases stem from multiple complaints against Judge Lorinda T. Mupas of the Municipal Trial Court (MTC) of Dasmariñas, Cavite. The charges include grave misconduct, corruption, and gross ignorance of the law. Specific allegations involve her dismissal of a drug case (People v. Marcelino Diana) on the pretext of an illegal search, despite the seizure of shabu, amid rumors of a P500,000 bribe. She was also accused of demanding bribes from lawyers, improperly utilizing court staff for personal chores, allowing her clerk of court to conduct preliminary investigations, and manipulating bail processes to extort money from detainees. A separate judicial audit also implicated Judge Dolores L. Español of the Regional Trial Court for issuing search warrants without the required written depositions.
ISSUE
Whether Judge Lorinda T. Mupas is administratively liable for the various acts of misconduct, corruption, and ignorance of the law alleged in the complaints.
RULING
Yes, Judge Mupas is administratively liable. The Court, adopting the findings of the investigating Justice, found substantial evidence to support the charges. Her dismissal of the drug case against Marcelino Diana constituted gross ignorance of the law. A judge conducting a preliminary investigation is tasked only to determine probable cause, not to rule on the admissibility of evidence, which is a judicial function for the trial proper. By dismissing the case based on the alleged illegality of the search, she arrogated a function not within her authority and effectively acquitted the accused without trial. This act, coupled with the serious allegations of bribery, evinces corrupt motives.
Furthermore, the allegations of demanding bribes, corrupt practices in bail proceedings, and misuse of personnel were substantiated by testimonial and documentary evidence. Such acts constitute grave misconduct and conduct prejudicial to the best interest of the service, eroding public confidence in the judiciary. The Court emphasized that a judge’s conduct must be beyond reproach. Judge Mupas’s actions demonstrated unfitness for judicial office. Consequently, she was found guilty of gross ignorance of the law, grave misconduct, and conduct prejudicial to the administration of justice. The Court ordered her DISMISSAL from service with forfeiture of all retirement benefits, except accrued leave credits, and with prejudice to re-employment in any government branch or instrumentality. The separate matter concerning Judge Español’s irregular issuance of search warrants was referred to the Office of the Court Administrator for further investigation.