G.R. No. A.M. No. MTJ-07-1676 January 29, 2009
AUREO G. BAYACA, Complainant, vs. JUDGE TRANQUILINO V. RAMOS, Respondent.

FACTS

Complainant Aureo G. Bayaca was the accused in Criminal Case No. 2479 for arson through reckless imprudence before the Municipal Circuit Trial Court (MCTC) of Dupax del Norte, Nueva Vizcaya, presided by respondent Judge Tranquilino V. Ramos. The MCTC found Bayaca guilty and sentenced him to imprisonment and to pay damages. On appeal, the Regional Trial Court (RTC) affirmed the conviction but modified the penalty, deleting the imprisonment and imposing only a fine and temperate damages. Despite the RTC’s deletion of the prison sentence, respondent Judge issued a Warrant of Arrest and Commitment on Final Sentence, which led to complainant’s incarceration at the Solano District Jail from August 8 to 28, 2006. Complainant filed an administrative complaint charging respondent Judge with gross misconduct, dishonesty, gross ignorance of the law, arbitrary detention, incompetence, grave abuse of discretion, and conduct prejudicial to the best interest of the service. Respondent Judge admitted the issuance was a mistake done in good faith, attributing it to a long-standing practice in his sala where his Clerk of Court would prepare orders for his signature. He also revealed that a civil case for damages filed against him by complainant had been dismissed and a criminal complaint was dismissed after complainant filed an Affidavit of Desistance, following a partial payment of ₱250,000.00 as part of an amicable settlement agreement for ₱750,000.00. The Office of the Court Administrator (OCA) found respondent Judge guilty of Negligence and Conduct Prejudicial to the Best Interest of Service and recommended a fine of ₱5,000.00.

ISSUE

Whether respondent Judge Tranquilino V. Ramos is administratively liable for issuing a warrant of arrest leading to complainant’s detention after the appellate court had deleted the penalty of imprisonment, and for entering into a monetary settlement for the withdrawal of cases against him.

RULING

The Supreme Court adopted the findings of the OCA, holding that respondent Judge was guilty of Negligence and Conduct Prejudicial to the Best Interest of Service. The Court emphasized that a judge must exercise extreme care in signing documents, especially warrants of arrest, as the liberty of an individual is at stake. Respondent Judge’s reliance on his staff was not an excuse and was an admission of incompetence. Furthermore, his act of giving money in exchange for the withdrawal of the civil, criminal, and administrative cases was highly improper, as administrative cases cannot be the subject of amicable settlement and their withdrawal does not divest the Court of its disciplinary authority. However, the Court noted that the case could be dismissed as respondent Judge had died prior to the promulgation of the Decision. Accordingly, the complaint was DISMISSED and the case considered CLOSED and TERMINATED.