AM RTJ 08 2145; (June, 2010) (Digest)
A.M. No. RTJ-08-2145; June 18, 2010
JUDGE MONA LISA T. TABORA, Complainant, vs. (Ret.) JUDGE ANTONIO A. CARBONELL, Respondent.
FACTS
This administrative case originated from a complaint by Caridad Tabisula against Judge Mona Lisa Tabora. Tabisula was the plaintiff in a civil case raffled to Judge Tabora’s branch. Due to Judge Tabora’s prolonged medical absence, the pairing judge, retired Judge Antonio Carbonell, took over the case, heard it from beginning to end, and eventually rendered a decision favorable to Tabisula. Upon Judge Tabora’s return, Tabisula repeatedly requested a copy of Judge Carbonell’s decision from the branch’s Officer-in-Charge, but was refused allegedly upon Judge Tabora’s instruction.
Judge Tabora instead issued an order requiring the parties to submit memoranda, asserting that the prerogative to decide the case remained with her as the presiding judge. She subsequently rendered her own decision, which was adverse to Tabisula. Tabisula then obtained a copy of Judge Carbonell’s favorable decision directly from him and filed the complaint, accusing Judge Tabora of maliciously altering a validly rendered decision by a court of equal jurisdiction and showing partiality, as the defendant bank was allegedly related to her husband.
ISSUE
Whether Judge Mona Lisa T. Tabora is administratively liable for her actions in handling the decision rendered by Pairing Judge Antonio A. Carbonell.
RULING
The Supreme Court found Judge Tabora guilty of Gross Ignorance of the Law and Gross Misconduct, and imposed a fine of P40,000. The legal logic is clear: under Circular No. 19-98, the authority of a pairing judge in a multi-sala court during the regular judge’s prolonged absence is expanded to include all matters, not just incidental ones. Judge Carbonell, as the pairing judge, validly assumed full authority over the case, including the power to hear it and render a decision. His decision was therefore valid and binding.
Judge Tabora’s failure to recognize this authority constituted gross ignorance of a basic and elementary rule. Her subsequent act of rendering a contrary decision, while knowingly withholding the earlier valid decision, was a deliberate disregard of judicial norms and procedure, amounting to gross misconduct. This act undermined the integrity of the judicial process. The Court emphasized that a judge is expected to exhibit more than just a cursory acquaintance with laws and procedures; failure to apply fundamental rules that are elementary and basic warrants administrative sanction. Her actions demonstrated not merely an error of judgment but a conscious disregard of duty and law.
