Ignacio v.

Valenzuela, 111 SCRA 12

Adm. Case No. 2252-CFI January 18, 1982

RUFINO IGNACIO, complainant,

vs.

HON. MANUEL E. VALENZUELA, Presiding Judge, Court of First Instance of Rizal, Branch XXIX, Pasay City,
respondent.

PONENTE: ABAD SANTOS, J.:

FACTS:

Judge of the CIF Pasay respondent Manuel Valenzuela charged of serious of misconduct by Rufino Ignacio,
a litigant in respondent’s sala. The charge is that the respondent took an undue personal interest in a case
by resolving favorably a motion to quash a temporary restraining order even though judge was on
vacation.

Among other person including Ignacio, filed an action for damages in the CIF of Rizal praying for a
restraining order status be pending the hearing on the merits. The Executive Judge (not the respondent)
issued a restraining order on May 2, 1979 and set the case on hearing on May 4 1979. Two days later, the
defendant of the case filed a motion to quash the restraining order which was duly opposed by the
plaintiffs. Afterwards, the case was raffled the Branch XXIX presided by the respondent Judge who was on
vacation from May 1-31, 1979, as shows in his certificate of service – New Judicial No. 89.

On May 8, 1979, the respondent judge heard the motion to quash the restraining order in his chamber
wearing only a polo jacket and latter, he granted the motion in the next day.

Ignacio and his co-plaintiffs questioned the legality in Court of Appeals that judge granted the motion
while he is on leave. The appeal was docketed as CA-GR No. 09226-SP and held the investigation against
the judge.

ISSUE: Whether or Not that respondent Judge took a misconduct and impropriety to hear and grant the
motion while he is on leave?

RULING: YES, during the investigation, it was found out that the respondent judge is guilty of impropriety.
It may seem that the respondent judge action is not as serious found to have been committed in
Fernandez v Presbitero. However, as recommendation, the judge was ordered to pay the fine equally to
his 1-month salary and sternly warned that repetition of his misconduct will place him in grave peril.
Sabitsana v. Villamor, 202 SCRA 445

A.M. No. 90-474 October 4, 1991

CLEMENCIO C. SABITSANA, JR., complainant

vs.

JUDGE ADRIANO R. VILLAMOR, RTC, BRANCH 16, NAVAL, LEYTE, respondent.

FACTS:

Atty. Sabitsana charged Judge Villamor with falsification of his monthly Certificates of Service by making
it appear that he had resolved all cases submitted for decision within the required 90-day period under
Judiciary Act of 1948, Sec. 5. The truth is he had 15 undecided cases from 5 years back (starting March
1985). The Deputy Court Administrator Bernad audited Villamor’s cases and reported that there were 87
undecided cases beyond the 90-day period, including 6 criminal cases with prisoners, 36 criminal cases
without prisoners, and 45 civil cases. Worse, 2 criminal cases and 12 civil cases were missing. The
complainant also noted 7 additional cases that were still unresolved by Villamor.

Commenting, Villamor claimed that the complaint was for harassment and vengeance. He claimed he had
not violated the 90-day period but did not deny that there were other cases he had not decided yet within
90 days because the transcripts were incomplete. He also added that he knew nothing of the preparation
of his monthly reports which appeared decided within 90 days when in fact they were not; and that he
only signed it. Among others, the Court ordered Villamor to decide unresolved cases beyond the 90-day
period, and to inform the Court about his steps in retrieving lost records. Villamor has been unheard from
on those directives. Sabitsana followed up with another complaint, stating that the 7 mentioned cases he
earlier mentioned remained undecided. The Court validated the complainant’s charge that Villamor failed
to decide the cases within the required period, and that he falsified his Certificates of Service. Villamor
shifted the blame on his Clerk of Court Atty. Jocobo, whom he claimed was inefficient in managing Court
records

ISSUE: Whether or not respondent Judge Villamor violated the Code of Judicial Conduct.

RULING: Yes. He violated Rule 3.08 of the Code of Judicial Conduct. As held in Secretary of Justice v
Legaspi, the judge ought to know the cases submitted to him for decision, particularly those pending for
more than 90 days. He should keep his own record of cases submitted for decision so that he could act on
them promptly. He should also be diligent and vigilant in preparing his monthly certificates of service by
verifying often whether there are pending cases for decision for more than 90 days, because he could be
held accountable for any error or falsification in his certificates. He cannot escape liability for falsification
of his certificates of service with the excuse that he has no knowledge of those cases pending decision for
more than 90 days. Nor could he blame his subordinate court employees for failing to remind him of his
deadlines—court employees are not the guardian of a judge’s responsibilities.
Marces, Sr. v. Arcangel, 258 SCRA 503

A.M. No. RTJ-91-712 July 9, 1996

BEN D. MARCES, SR., complainant,

vs.

JUDGE PAUL T. ARCANGEL, Presiding Judge, Branch 12, Regional Trial Court Davao City, respondent.

PONENTE: MENDOZA, J.:

FACTS:

The case is about the family feud between Marces Family and Spouse Cañas. A 61year-old retiree, married
to Ruth Jovellor and their 5 children residing in BRC Village, Catalunan Penqueño, Davao City.

Sometimes in 1984, Spouses Wilfredo and Flordeliz Cañas moved into the complainant’s neighborhood.
They become friends in the latter. In the same year, the domestic helper of Cañases sought the
complainant’s help for alleged maltreatment. As the complainant was the Purok Leader in their place, he
referred the matter to Barangay authorities. The complaint of the domestic helper was resolved.
However, the friendship between the two families became restrained.
On September 28, Mrs. Cañases, together with her sister and a neighbor, boarded a passenger jeepney
despite the fact that there were no more seats available because the complainant was riding in that
vehicle. It turned out that Mrs. Cañas had intended to cause the complainant’s arrest because as the
jeepney neared the police stations, Mrs. Cañas asked the driver to stop the vehicle. Mrs. Cañas then got
off and called a policeman and had the complaint, Ben D. Marces was arrested due to alias warrants of
arrest. The warrant has been issued by MTCC Judge Edipolo Sarabia in three criminal cases against herein
complainant for violation of Batas Pambansa Blg. 22Complainant was detained for one night without the
knowledge of his family a fact of which Mrs. Cañas allegedly boasted in the neighborhood.

Judge Sarabia inform the complainant that the alias warrant of arrest is far beyond the knowledge of judge
Sarabia; and Judge Paul Arcangel is behind the arrest.

As to the allegation of the family of the complainant, that Judge Arcangel is supporting the Sps Cañas,
every complaint of family Marces is screened to Judge Arcangel he has a personal interest in the case of
family Cañases.

ISSUE: Whether or Not that Judge Arcangel acts misconduct and harassment against the complainant.

RULING: Yes, during the investigation, the respondent judge was found guilty of improper conduct. Also,
the Court does not agree with the complaint due to a lack of justified evidence against judge Arcangel.
However, according to the Sabitsana Jr, v Villamor that the respondent was found guilty of attempting to
influence another judge or entity to be accused in a criminal case, and in addition, of making untruthful
statements in the certificate of services. At this juncture, the allegation of the respondent judge could not
be present and justified by the complainants. As per the ruling of the court, the respondent judge cannot
be charged against the alleged committed act. However, the respondent judge is hereby reprimanded
with a Warning that the commission of a similar act on his part in the future will be a deal more severe.
All charges are hereby Dismissed.