G.R. No. A.M. No. MTJ-23-014 (Formerly JIB FPI No. 21-024-MTJ), April 11, 2024
Hon. Sharon Magayanes, Vice Executive Judge/Presiding Judge, Branch 3, Municipal Trial Court in Cities [MTCC], Calamba City, Laguna, Complainant, vs. Hon. Leah Angeli B. Vasquez-Abad, Executive Judge/Presiding Judge, Branch 1, MTCC, Calamba City, Laguna, Respondent.

(Consolidated with A.M. No. MTJ-23-015, A.M. No. MTJ-24-026, and A.M. No. MTJ-24-027)

FACTS

The cases involve administrative complaints between judges of the MTCC, Calamba City. In A.M. No. MTJ-23-014, Judge Sharon Alamada-Magayanes (Judge Alamada) charged Executive Judge Leah Angeli Vasquez-Abad (Judge Abad) with Gross Ignorance of the Law and Rules of Procedure. The complaint stemmed from Judge Abad’s actions on April 22, 2021, where she motu proprio dismissed three criminal cases (Criminal Case Nos. 65207-21, 65209-21, and 65210-21) against Jeffrey Ostil Tamayo after he applied for bail, but before the cases were raffled. Judge Alamada argued that an Executive Judge, prior to raffle, has no adjudicatory power to determine probable cause or dismiss cases, citing administrative circulars and the ruling in Crespo v. Mogul. She noted a similar prior incident in 2018. Judge Abad, in her defense, claimed good faith, stating her actions were based on an “ingrained practice” of evaluating cases upon filing, especially when bail is applied for. She cited OCA Circular No. 89-2020 (which instituted a Judge-on-Duty system during the pandemic) and OCA Circular No. 94-2020 (which resumed regular raffles “as far as practicable”) as justifications. She later recalled her dismissal orders on April 3, 2022, after seeking clarification from the Office of the Court Administrator (OCA), which, through Court Administrator Raul Villanueva, stated that an Executive Judge cannot act on bail applications or determine probable cause for unraffled cases.

ISSUE

Whether Judge Leah Angeli B. Vasquez-Abad is administratively liable for Gross Ignorance of the Law and Rules of Procedure for motu proprio dismissing criminal cases prior to their raffle.

RULING

Yes, Judge Abad is administratively liable. The Supreme Court found her guilty of Gross Ignorance of the Law, a serious charge under Rule 140 of the Rules of Court. The Court emphasized that the power to determine probable cause in cases filed directly with the court is an adjudicative function belonging solely to the judge to whom the case is raffled. An Executive Judge’s role prior to raffle is purely administrative. Judge Abad’s reliance on pandemic-era circulars was misplaced, as OCA Circular No. 94-2020 had already discontinued the Judge-on-Duty arrangement and reinstated the regular raffle procedure. Her claim of good faith was rejected, as her actions constituted a patent disregard of clear and established rules, which is constitutive of gross ignorance. The Court noted that her subsequent recall of the orders did not absolve her of liability. Accordingly, Judge Abad was DISMISSED 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 Court also found other judges and court personnel involved in the consolidated cases liable for various offenses including Gross Misconduct, Dishonesty, and Gross Neglect of Duty, imposing penalties ranging from dismissal, suspension, fines, to reprimand.