A.M. No. MTJ-17-1897, November 21, 2018
Ma. Victoria S.D. Carpio and John Persius S.D. Carpio, Complainants, vs. Judge Elenita C. Dimaguila, Municipal Trial Court in Cities of Antipolo City, Rizal, Branch 4, Respondent.

FACTS

Respondent Judge Elenita C. Dimaguila presided over Criminal Case No. 14-0504 for Grave Coercion against complainants Ma. Victoria S.D. Carpio and John Persius S.D. Carpio. Complainants filed an administrative complaint for Gross Ignorance of the Law, alleging that the judge refused to refer the case to the mandatory Court-Annexed Mediation (CAM) and Judicial Dispute Resolution (JDR) as required by A.M. No. 11-1-6-SC-PHILJA. In her defense, Judge Dimaguila asserted she was aware of the guidelines but opted not to refer the case because the complainants had categorically declared in open court their disinterest in settling the civil aspect. She argued this was to avoid further delay in the proceedings.
The Office of the Court Administrator (OCA) recommended finding the judge guilty of Gross Ignorance of the Law and imposing a fine of P10,000.00, noting the mandatory nature of the referral but considering her lack of prior offenses as a mitigating circumstance. The Court adopted this recommendation in a Resolution dated April 17, 2017. Judge Dimaguila filed a Motion for Reconsideration, arguing her deviation was slight and justified, not borne from ignorance, as she regularly issues such referrals in other cases.

ISSUE

Whether the Court’s Resolution finding Judge Dimaguila guilty of Gross Ignorance of the Law should be reconsidered.

RULING

Yes, the Motion for Reconsideration is partly granted. The Court modified the finding from Gross Ignorance of the Law to the less serious charge of Violation of Supreme Court Rules, Directives, and Circulars. Gross Ignorance of the Law requires that an erroneous judicial act be motivated by bad faith, dishonesty, or some corrupt motive. The records show Judge Dimaguila was familiar with and regularly implemented the CAM/JDR rules in other cases, evidenced by her standing orders referencing A.M. No. 11-1-6-SC-PHILJA. Her failure to refer this specific case, based on her perception that settlement was futile given the parties’ expressed disinterest, was an error in judgment but not an act of gross ignorance.
However, the Court upheld her administrative liability. The requirement for referral in cases involving the civil aspect of less grave felonies is mandatory under A.M. No. 11-1-6-SC-PHILJA and admits no exception based on the parties’ perceived disinterest. By deviating from this strict procedure, she violated a Supreme Court circular. Considering the absence of bad faith and that this was her first offense, the penalty was mitigated. The fine of P10,000.00 was reduced to a REPRIMAND with a stern warning. Judge Dimaguila was reminded to be more circumspect and to discharge her duties in strict compliance with issued rules and circulars.