AM MTJ 94 1012; (March, 1995) (Digest)
A.M. No. MTJ-94-1012. March 20, 1995. JOHAN L.H. WINGARTS and OFELIA A. WINGARTS, complainants, vs. JUDGE SERVILLANO M. MEJIA, respondent.
FACTS
Complainants Johan and Ofelia Wingarts filed three administrative complaints against Judge Servillano M. Mejia of the Municipal Trial Court of Santa Maria, Pangasinan. The complaints stemmed from three related criminal cases. The first charge alleged malicious delay in the administration of justice in Criminal Case No. 2663 for malicious mischief, which took over a year to resolve. The second charge accused the judge of incompetence and ignorance of the law for taking cognizance of Criminal Case No. 2664 for grave threats and issuing a warrant of arrest despite the absence of prior barangay conciliation, a jurisdictional requirement. The third charge alleged that the judge rendered an unjust decision in Criminal Case No. 2696 for usurpation of authority by acquitting two military lawyers.
Respondent judge defended his actions. For the delay, he argued the proceedings were continuous and the case was decided shortly after submission. Regarding the barangay conciliation issue, he believed a certification from the barangay captain constituted substantial compliance, though he later dismissed the case upon motion. For the acquittal, he maintained it was based on his honest evaluation of the evidence and law.
ISSUE
Whether respondent Judge Servillano M. Mejia is administratively liable for the charges of delay, ignorance of the law for failing to observe the Katarungang Pambarangay Law, and rendering an unjust judgment.
RULING
The Court found respondent judge administratively liable for ignorance of the law concerning the second charge but not liable for the charges of delay and rendering an unjust judgment. On the first charge, the delay was not found to be malicious or deliberate, as postponements were often due to the unavailability of counsel or the fiscal, not the judge’s own making. On the third charge, for a judge to be held liable for knowingly rendering an unjust judgment, it must be proven beyond reasonable doubt that the decision was not supported by law or evidence and was made with conscious and deliberate intent to do an injustice, such as being motivated by hatred or revenge. Complainants failed to provide such convincing proof.
However, the Court upheld the second charge. The judge exhibited ignorance of a basic procedural law. Under the Revised Katarungang Pambarangay Law (Local Government Code of 1991), offenses punishable by imprisonment not exceeding one year or a fine not exceeding P5,000.00, which includes grave threats, require prior barangay conciliation as a precondition for filing in court. The judge’s act of taking cognizance of the case and issuing a warrant without verifying strict compliance with this mandatory condition was a clear disregard of established law. While his action was not tainted with malice, such failure constitutes gross ignorance of the law or procedure. Municipal trial judges, being at the forefront of the judiciary, must act with constant probity and competence to maintain public faith. Accordingly, respondent Judge Servillano M. Mejia was ordered to pay a fine of Two Thousand Pesos (P2,000.00) with a stern warning.