Lapeña v. Collado
REITERATIONFacts
1. The Antecedents: The underlying dispute involved two civil cases for forcible entry filed by Felicidad Guerra Vda. de Lapeña against several individuals in the Municipal Court of Bautista, Pangasinan. These cases, docketed as Civil Cases Nos. 382 and 383, included prayers for preliminary injunctions to prevent further dispossession and disturbance of the complainant's possession of the land in question. Additionally, in Civil Case No. 382, a motion and an amended motion were filed requesting the deposit and sale of harvested corn and tobacco crops during the pendency of the case. 2. Procedural History: The respondent, Municipal Judge Jose L. Collado, was charged with falsifying certifications on July 2, 1973, and August 1, 1973, by falsely attesting that all petitions and motions submitted to him for determination within ninety days had been resolved. These certifications were necessary for him to collect his salary for those months. The verified complaint was forwarded to the District Judge of the Court of First Instance of Pangasinan for investigation, who subsequently submitted a report with findings of fact to the Supreme Court. The investigating judge found that while the resolution of the motion concerning crop deposit was properly deferred, the petition for preliminary injunction in Civil Case No. 382 had not been resolved by the ninety-day mark, thus constituting a falsehood in the certification dated August 1, 1973. The judge also noted that the Municipal Court of Bautista was a court of record and that the respondent's claim of not issuing written orders because it was not a court of record was untenable. 3. The Petition: The complainant alleged that respondent Municipal Judge Jose L. Collado committed multiple falsifications of public documents by issuing certifications on July 2 and August 1, 1973, falsely stating that all petitions and motions under submission for ninety days or more had been determined. The complainant contended that the petitions for preliminary injunction in Civil Cases Nos. 382 and 383, as well as the motion and amended motion for crop deposit in Civil Case No. 382, remained unresolved on those dates. The Supreme Court, however, exonerated the respondent, finding the single instance of falsehood to be due to carelessness or negligence rather than malice or bad faith, and admonished him to act with due care in executing Certificates of Service.
Issue(s)
Whether the Respondent Judge committed serious misconduct by falsely certifying that all motions and petitions had been resolved within the 90-day period. Whether the status of the Municipal Court as 'not a court of record' is a valid defense for the failure to issue written orders resolving motions.
Ruling
The respondent Municipal Judge Jose L. Collado is exonerated of the charges against him but is admonished to act with due care in executing his Certificates of Service.
Ratio Decidendi
On Issue 1: Regarding Civil Case No. 382, the Court found that the ninety-day period for the injunction petition commenced on April 3, 1973, and expired on July 2, 1973. By certifying on August 1, 1973, that all matters were resolved, the Respondent Judge technically committed a falsehood as the petition remained pending. However, the Court ruled that this single aberration did not spring from malice or bad faith. Instead, the error was attributed to carelessness, negligence, or an over-reliance on the judge's employees. Under the circumstances, such a false statement cannot be classified as serious misconduct. Following the precedent in Secretary of Justice v. Bullecer (56 SCRA 25), the Court emphasized that while promptness is vital, the penalty must be commensurate with the nature of the lapse. On Issue 2: The Respondent's contention that he was not required to issue written orders because his court was not a court of record was flatly rejected. The Court noted that pursuant to Republic Act No. 6031 (RA 6031), the Municipal Court of Bautista was already a court of record and employed an official stenographer to document proceedings. Even if it were not a court of record, the duty to manifest fidelity to the trust reposed in him requires a judge to have an adequate grasp of statutory provisions and legal doctrines. The Court observed that if the injunction had truly been denied in open court, there would have been no need for the judge to later assure the complainant of its potential issuance. Therefore, the failure to issue written orders was a breach of proper judicial system and procedure. Ultimately, the judge must act with dispatch to ensure that the people's faith in the administration of justice is not impaired.
Main Doctrine
A municipal judge who falsely certifies that all petitions and motions submitted to him for determination within a ninety-day period have been resolved, when in fact they have not, commits a falsehood. However, if such falsehood is due to carelessness, negligence, or reliance upon an employee, and not malice or bad faith, it may not be classified as serious misconduct, but the judge should be admonished to act with due care.