G.R. No. MTJ-92-678 February 24, 1994
OLIVIA BAMBO-JORIN, complainant, vs. JUDGE ARNULFO A. SINGSON, respondent.

FACTS

Complainant Olivia L. Bambo-Jorin filed a sworn letter-complaint against Judge Arnulfo A. Singson of the Municipal Trial Court of Tanay, Rizal, for alleged negligence, knowingly rendering an unjust judgment, incompetence, and ignorance of the law in Criminal Cases Nos. 5714 and 5715 (“People of the Philippines vs. Teresita Sabiniano”) for Slight Physical Injuries and Oral Defamation. The complaint alleged irregularities: (1) the issuance of a Notice of Promulgation of Judgment dated April 1, 1992, for a promulgation set on April 6, 1992, despite the decision being dated April 2, 1992; (2) the imposition of a penalty of arresto menor without specifying the period for the slight physical injuries case and a fine of P200.00 for the oral defamation case, without considering the accused’s profession as a teacher; (3) the resetting of trial proceedings on several occasions for periods longer than one month without the written authority of the Chief Justice; and (4) the issuance of an Order dated April 12, 1992, directing the accused to report to the Probation Officer without giving the trial prosecutor an opportunity to comment. In his Comment, respondent Judge argued the date discrepancy was a clerical error by his stenographers, admitted the adjournments were longer than allowed but claimed they were with the consent of both counsel, averred the fine imposition was discretionary, admitted the oversight in not specifying the penalty period due to a hurried decision, and stated notice to the prosecutor was not required for the probation application.

ISSUE

Whether respondent Judge Arnulfo A. Singson is administratively liable for the alleged irregularities in handling Criminal Cases Nos. 5714 and 5715.

RULING

The Supreme Court found respondent Judge administratively liable for negligence in the improper imposition of the penalty in the slight physical injuries case. The Court held that under Article 266(2) and (3) of the Revised Penal Code, the penalty for slight physical injuries is arresto menor or a fine, not both, and the period of arresto menor should have been specified. The imposition of a fine of P200.00 in the oral defamation case was within the judge’s discretion under Article 358 of the Revised Penal Code, and the accused’s financial capability is immaterial. The Court found no evidence of bad faith but noted negligence. Respondent Judge Arnulfo Singson was REPRIMANDED with a WARNING that a repetition of a similar infraction would be dealt with more severely.