AM MTJ 99 1234; (October, 2000) (Digest)
G.R. No. MTJ-99-1234; October 16, 2000
ATTY. JESUS G. CHAVEZ, complainant, vs. JUDGE PANCRACIO N. ESCAÑAN, respondent.
FACTS
Complainant Atty. Jesus G. Chavez, a Public Attorney’s Office lawyer, filed an administrative complaint against respondent Judge Pancracio N. Escañan for Gross Ignorance of the Law. The charges stemmed from several cases. In Criminal Case No. 3128 for Homicide through Reckless Imprudence, the judge issued orders to implead the vehicle’s owner as an accused. In Criminal Case No. 7074 for Frustrated Homicide, he issued a warrant of arrest based primarily on the victim’s wife’s hearsay testimony. In a civil recovery case, he denied a motion to dismiss on the same day an opposition was received and later declared the defendant in default for late arrival. The complainant later filed a supplemental comment alleging additional irregularities, including falsification of an order and improper dismissal of cases.
ISSUE
Whether respondent Judge Pancracio N. Escañan is administratively liable for Gross Ignorance of the Law.
RULING
Yes, the Supreme Court found respondent judge administratively liable, specifically for his order to implead the vehicle owner in the criminal case for reckless imprudence. The Court, adopting the findings of the Office of the Court Administrator, held that while a judge is generally not liable for erroneous official acts done in good faith, respondent exhibited a fundamental ignorance of settled law. Jurisprudence clearly establishes that the liability of a vehicle owner arising from a vehicular accident is civil, not criminal, and thus the owner cannot be impleaded as an accused in such a criminal case. This error was deemed so gross and patent as to constitute ignorance of the law. The Court emphasized that judges must maintain professional competence and have a proficient grasp of basic legal principles. The other charges, such as falsification and improper dismissal, were not substantiated by sufficient evidence. Accordingly, the Court imposed a fine of Five Thousand Pesos (₱5,000.00) with a warning that a repetition would be dealt with more severely.