AM MTJ 03 1506; (August, 2003) (Digest)
A.M. No. MTJ-03-1506; August 28, 2003
Pablo B. Mabini, Complainant, vs. Judge Lorinda B. Toledo-Mupas, Municipal Trial Court, Dasmariñas, Cavite, Respondent.
FACTS
Complainant Pablo B. Mabini filed an administrative complaint against respondent Judge Lorinda B. Toledo-Mupas for Abuse of Authority and Ignorance of the Law concerning Criminal Case No. 98-0939 for Frustrated Homicide. The respondent judge conducted a preliminary investigation, found probable cause for Frustrated Homicide, and forwarded the case to the Office of the Provincial Prosecutor. The prosecutor subsequently downgraded the charge to Attempted Homicide and returned the case with the corresponding Information to the respondent judge’s court, as the offense fell within its jurisdiction.
The complainant alleged that the preliminary investigation was improperly conducted by the judge instead of a public prosecutor. He further argued that the case, having originated from a charge for Frustrated Homicide, should have been forwarded to the Regional Trial Court (RTC) of Imus after the prosecutor’s action, suspecting wrongdoing when it remained with the Municipal Trial Court (MTC).
ISSUE
Whether respondent Judge Lorinda B. Toledo-Mupas is administratively liable for Abuse of Authority and Ignorance of the Law for conducting a preliminary investigation and for the case being tried in her court after the charge was downgraded to Attempted Homicide.
RULING
The Supreme Court dismissed the complaint for lack of merit. The Court clarified that under Rule 112, Section 2 of the 2000 Revised Rules of Criminal Procedure, judges of Municipal Trial Courts are expressly authorized to conduct preliminary investigations for crimes cognizable by the proper courts within their territorial jurisdictions. The respondent judge’s act of conducting the preliminary investigation was therefore legally sound and within her authority.
The Court emphasized that in administrative proceedings, the burden of proof lies with the complainant to establish the allegations by substantial evidence. The presumption of regularity in the performance of official duties stands in the absence of contrary evidence. The record failed to show any wrongful, improper, or unlawful conduct on the part of the respondent judge. Even assuming an error was committed, it would constitute a mere error of judgment for which a judge cannot be held administratively liable in the absence of a showing of bad faith, malice, or corrupt purpose. Judges cannot be penalized for erroneous decisions rendered in good faith.