AM RTJ 03 1794; (October, 2005) (Digest)
G.R. No. RTJ-03-1794 October 25, 2005
P/Supt. Manuel P. Barcena vs. Judge Henrick F. Gingoyon
FACTS
Complainant P/Supt. Manuel P. Barcena charged respondent Judge Henrick F. Gingoyon with gross ignorance of the law, grave abuse of authority, and bias. The case stemmed from two criminal cases for violation of the Dangerous Drugs Act where the accused were acquitted via a demurrer to evidence. Respondent judge, thereafter, gave due course to the prosecution’s notice of appeal from the judgment of acquittal. He also issued orders concerning vehicles seized as evidence, placing them in the custody of court sheriffs. Complainant later found one vehicle being used personally by a sheriff and, after towing it for verification, was issued a show-cause order for contempt by the respondent judge. Complainant alleged the judge’s actions demonstrated ignorance for allowing an appeal of an acquittal, abuse for permitting misuse of evidence, and bias for the swift contempt proceedings.
ISSUE
Whether respondent Judge Henrick F. Gingoyon is administratively liable for gross ignorance of the law and for improper conduct in handling court exhibits and contempt proceedings.
RULING
Yes, respondent is liable for gross ignorance of the law but not for grave abuse of authority or bias. The Supreme Court found that giving due course to a notice of appeal from a judgment of acquittal constituted gross ignorance of a fundamental and elementary rule. A judgment of acquittal is immediately final and cannot be appealed, as it would place the accused in double jeopardy. The judge’s defense of judicial activism and good faith was unavailing; basic procedural rules are mandatory, and deviation therefrom, especially on a settled constitutional principle, manifests ignorance. However, the charges of grave abuse of authority and bias were not substantiated. The act of entrusting seized vehicles to sheriffs for safekeeping, while irregular for lacking proper safeguards, did not by itself prove the judge authorized personal use. The swift issuance of the show-cause order, while indicative of undue haste, did not conclusively establish partiality or prejudgment. For gross ignorance, a fine of Twenty Thousand Pesos (₱20,000.00) was imposed with a stern warning. For the lack of care in handling exhibits, he was admonished to exercise greater diligence.