G.R. No. MTJ-98-1155 July 31, 1998
Dolores Gomez, complainant, vs. Judge Rodolfo A. Gatdula, MTC, Balanga, Bataan, respondent.

FACTS

Complainant Dolores Gomez filed letter-complaints charging respondent Judge Rodolfo A. Gatdula with gross incompetence, grave abuse of authority, and acts unbecoming a member of the judiciary. The charges arose from incidents in two criminal cases: Criminal Case No. 5988 (People v. Armando Reyes) for reckless imprudence, where the complainant’s husband was the offended party, and Criminal Case No. 5917 (People v. Socorro Du) for falsification, where Dolores Gomez herself was the complainant. In the reckless imprudence case, complainant alleged that during preliminary investigation, respondent judge tried to dissuade her from pursuing the case, asked her to reduce her monetary claim, and refused to issue a warrant of arrest, claiming lack of authority. She also alleged that the original complaint omitted the homicide and serious injuries, which was later amended through a prosecutor’s intercession, and that key witnesses were not listed after being promised no subpoenas. Regarding the falsification case, after complainant requested a transfer of venue, respondent judge canceled hearings for both cases and delayed filing his comment on the transfer request for five months, effectively suspending proceedings. Respondent judge denied the allegations, claiming the postponements were upon complainant’s request, that he informed her a warrant could not be issued as preliminary investigation was not terminated, and that he had no objection to the transfer but wanted both cases included. He alleged complainant was motivated by his refusal to help her secure damages and a prior loss in an ejectment case.

ISSUE

Whether respondent Judge Rodolfo A. Gatdula is administratively liable for oppression and acts unbecoming a judge based on the allegations and evidence presented.

RULING

The Court found respondent Judge Rodolfo A. Gatdula guilty of oppression and acts unbecoming a judge. He was not held liable for the allegations of dissuading the complainant or refusing to issue a warrant, as the preparation of the complaint was the investigating officer’s duty and a warrant could only be issued after preliminary investigation if probable cause existed. However, the Court found he acted vindictively and oppressively by suspending proceedings in both cases and deliberately delaying the filing of his comment on the motion for transfer of venue for five months, which caused undue delay in the disposition of the cases. This conduct failed to meet the standard of being free from the appearance of impropriety and beyond reproach as required by judicial ethics. Respondent judge was ordered to pay a fine of P10,000.00 with a warning that repetition would be dealt with more severely.