AM RTJ 05 1960; (October, 2005) (Digest)
G.R. No. RTJ-05-1960. October 25, 2005.
JUVELYN D. KILAT, Complainant, vs. JUDGE MARIANO S. MACIAS, Respondent.
FACTS
Complainant Juvelyn D. Kilat, then a minor, charged respondent Judge Mariano S. Macias with rape, immorality, and related offenses. She alleged that the judge sexually assaulted her on multiple occasions, starting in 1999, using threats and monetary inducements. The respondent judge denied all accusations, claiming the complaint was a fabrication orchestrated by his ex-wife and local officials with personal grievances against him. He presented sworn statements from the complainant recanting her allegations and claiming she was kidnapped and coerced into filing the case.
Subsequently, a criminal complaint for kidnapping and coercion was filed by the complainant against the alleged conspirators, including the judge’s ex-wife. This case was docketed as Criminal Case No. L-00727 and was raffled to the respondent judge’s own court, RTC Branch 28, Liloy. The judge then issued warrants of arrest against all the accused, including his ex-wife, before eventually inhibiting himself from the case upon the accused’s motion.
ISSUE
Whether respondent Judge Mariano S. Macias is administratively liable for his actions in relation to the criminal case filed against the parties he accused of conspiring against him.
RULING
Yes, the respondent judge is administratively liable for abuse of authority and violation of mandatory inhibition rules. The Supreme Court dismissed the charges for immorality and rape due to insufficiency of evidence, heavily influenced by the complainant’s recantation. However, the Court found the judge liable for his conduct in Criminal Case No. L-00727.
The legal logic is clear: a judge must avoid any appearance of impropriety. Under Section 1, Rule 137 of the Rules of Court, mandatory inhibition is required when a judge has a personal bias or prejudice concerning a party. The respondent judge was the complainant in the very kidnapping case assigned to his court, and the accused included his ex-wife, with whom he had a contentious relationship. By proceeding to issue arrest warrants, he exhibited bias and abused his authority. He should have immediately inhibited himself ab initio to preserve the integrity and impartiality of the proceedings. His actions constituted a violation of Supreme Court rules, a less serious charge under Rule 140. Consequently, the Court imposed a fine of Twenty Thousand Pesos (₱20,000.00).