A.M. No. RTJ-92-876 September 19, 1994
State Prosecutors vs. Judge Manuel T. Muro, Regional Trial Court, Branch 54, Manila

FACTS

State Prosecutors charged respondent Judge Manuel T. Muro with ignorance of the law, grave misconduct, and violations of the Code of Judicial Conduct. The complaint stemmed from the judge’s Order dated August 13, 1992, which dismissed eleven criminal cases for violation of foreign exchange restrictions against Imelda Marcos. The judge based his dismissal solely on newspaper reports from August 11, 1992, which quoted the President’s announcement on August 10 regarding the lifting of such restrictions. The judge concluded that this announcement effectively repealed the relevant Central Bank Circular, thereby depriving his court of jurisdiction. He dismissed the cases motu proprio without requiring the prosecution’s comment, despite pre-scheduled trial dates, and before any official Central Bank circular or Monetary Board resolution was issued or published.
In his comment, the respondent judge contended that the President’s public announcement was total and immediately effective, and he acted on the belief that it rendered the cases moot. He argued he could not be faulted for relying on the announcement, which was only later clarified.

ISSUE

Whether respondent Judge Manuel T. Muro is administratively liable for gross ignorance of the law and grave misconduct for dismissing criminal cases based solely on newspaper reports of a presidential announcement, prior to the official issuance and publication of the relevant regulatory change.

RULING

Yes, the Supreme Court found the respondent judge guilty of gross ignorance of the law and ordered his dismissal from service. The legal logic is clear and multi-faceted. First, a judge is mandated to be proficient in the law and must know that laws and administrative issuances like Central Bank circulars only become effective upon official publication in the Official Gazette or a newspaper of general circulation. The judge’s reliance on uncorroborated newspaper accounts as a basis for judicial notice of a legislative or executive act, before its official publication, constitutes a fundamental and gross misapplication of the rules on judicial notice and the doctrine of due process. Second, his motu proprio dismissal of the cases was procedurally improper and denied the prosecution its right to be heard, violating basic tenets of fair play. The haste of his action, ignoring set trial dates, demonstrated not mere error but a cavalier disregard for settled legal principles. Such actions erode public faith in the judiciary. The Court emphasized that a judge owes a continuous duty to know and correctly apply the law; failure in this duty, especially when the lapse is so grave and patent, warrants the ultimate administrative penalty of dismissal.