G.R. No. MTJ-03-1469; January 13, 2003
Rolando Guyud, complainant, vs. Judge Renato P. Pine, Municipal Trial Court, Echague, Isabela, respondent.
FACTS
Complainant Rolando Guyud and eight others were charged with libel before the Municipal Trial Court (MTC) of Echague, Isabela, presided by respondent Judge Renato P. Pine. The accused filed a motion to dismiss, arguing that under Article 360 of the Revised Penal Code, as amended, only the municipal trial court judge in the capital town of the province or the provincial prosecutor could conduct the preliminary investigation for libel. Since Echague is not the capital of Isabela, respondent allegedly lacked authority. Respondent denied the motion, proceeded with the preliminary investigation, and issued warrants of arrest against the accused, who were then arrested while attending a court hearing.
The following day, the accused secured a reduction of their bail and were released. Subsequently, on September 19, 2001, respondent issued an order recalling the warrants and remanding the case to the Provincial Prosecutor for proper preliminary investigation, acknowledging that his court lacked jurisdiction under Article 360. In his comment, respondent admitted his error, attributing it to a heavy workload, and emphasized his prompt corrective action.
ISSUE
Whether respondent Judge Renato P. Pine is administratively liable for Gross Ignorance of the Law for conducting a preliminary investigation and issuing warrants of arrest in a libel case despite lacking jurisdiction under Article 360 of the Revised Penal Code.
RULING
Yes, respondent is guilty of Gross Ignorance of the Law. The Supreme Court held that judges are expected to have a basic mastery of fundamental legal principles. Article 360 of the Revised Penal Code explicitly vests jurisdiction to conduct preliminary investigations in libel cases either with the provincial or city prosecutor or with the municipal trial court judge of the province or city’s capital. Echague not being the capital of Isabela, respondent’s MTC clearly lacked jurisdiction. His act of proceeding despite a timely challenge demonstrated a failure to apply a clear and elementary rule, constituting gross ignorance.
The Court rejected respondent’s defense of a heavy workload, stating that such pressure does not excuse ignorance of a basic, settled law. However, his liability was mitigated by his candor in admitting the mistake and his prompt corrective action in recalling the warrants and remanding the case, which showed no ill motive or bad faith. Considering these mitigating circumstances and analogous precedents, the Court imposed a fine of Five Thousand Pesos (P5,000.00) with an admonition to be more diligent. The penalty balances the need to uphold judicial competence with recognition of his subsequent rectification.
