A.M. No. RTJ-07-2037; June 30, 2008
Atty. Norito E. Torres, et al., complainants, vs. Judge Irma Zita V. Masamayor, respondent.

FACTS

Complainants were accused of sedition before the Regional Trial Court of Talibon, Bohol, Branch 52, presided by respondent Judge Irma Zita V. Masamayor. Their counsel filed an urgent motion for judicial determination of probable cause and to hold the issuance of a warrant of arrest in abeyance on July 11, 2006. When a complainant appeared in court on July 14, 2006 to argue the motion, the respondent judge informed him that an order finding probable cause and a corresponding warrant of arrest had already been issued. The copy of the warrant provided was dated July 5, 2006, while the order finding probable cause was dated July 10, 2006. This discrepancy led complainants to file an administrative complaint charging the judge with grave abuse of authority, gross ignorance of the law, grave misconduct, bias, and violation of the Anti-Graft and Corrupt Practices Act.
In her defense, respondent judge explained that the warrant dated July 5 was a clerical error. The court typist had used an old format saved on a computer and failed to update the date. Upon discovery, this erroneous warrant was discarded. The correct warrant, dated July 10, 2006, was the one actually issued and received by the Philippine National Police. She attributed the distribution of the erroneous copy to a mistake by her personnel.

ISSUE

Whether respondent Judge Irma Zita V. Masamayor is administratively liable for the charges of grave abuse of authority, gross ignorance of the law, grave misconduct, bias, and graft, or for negligence in supervising court personnel.

RULING

The Supreme Court dismissed the serious charges against the respondent judge but found her administratively liable for simple negligence in the supervision of court personnel. The Court expressly ruled that the respondent did not commit grave abuse of authority, gross ignorance of the law, grave misconduct, obvious bias and partiality, or a violation of Republic Act No. 3019 . The evidence, including certifications from the PNP and an affidavit from the docket clerk, substantiated the judge’s explanation that the warrant of arrest was correctly issued on July 10, 2006, contemporaneous with the order finding probable cause. The July 5 date was a mere clerical oversight that did not indicate a violation of the constitutional requirement that a warrant issue only upon a judicial determination of probable cause.
However, the Court upheld the recommendation of the Office of the Court Administrator that the respondent violated Rule 3.09, Canon 3 of the Code of Judicial Conduct, which requires a judge to organize and supervise court personnel to ensure prompt and efficient service. The laxity of her staff in preparing and inadvertently distributing an erroneously dated court document reflected a failure of proper supervision. A judge bears responsibility for the mistakes of subordinates and must exercise diligence in overseeing court operations to maintain public confidence in the judiciary. For this lapse, the Court imposed a fine of Two Thousand Pesos (P2,000.00) with a stern warning.