Mabutas v. Nable
REITERATIONFacts
The Antecedents: Complainant Domingo Mabutas, a retired court stenographer, filed an administrative complaint against Atty. Pilar P. Nable and former Assistant City Fiscal Rufino G. Madarang for alleged harassment. Mabutas claimed Nable maliciously charged him with Falsification of Public Document in an affidavit, alleging he falsified his daily time record on July 3, 1968, by stating he rendered service when he was actually attending a criminal case in Calapan, Oriental Mindoro. Mabutas asserted the charge was unfounded and retaliatory for his filing of damage suits against Nable and her family. Respondent Madarang issued a subpoena for Mabutas to appear at a preliminary investigation, compelling Mabutas to travel to Manila despite his age and condition. Procedural History: The case originated from an administrative complaint filed by Domingo Mabutas against Atty. Pilar P. Nable and former Assistant City Fiscal Rufino G. Madarang before the Supreme Court. The Petition: The complainant sought disciplinary action against the respondents for alleged harassment and malicious prosecution.
Issue(s)
Whether the respondents acted with malice and bad faith in filing and prosecuting the charge of falsification of public document against the complainant. Whether the actions of the respondents constituted harassment.
Ruling
The administrative complaint filed by Domingo Mabutas against respondents Atty. Pilar P. Nable and former Assistant City Fiscal Rufino G. Madarang is dismissed.
Ratio Decidendi
On the issue of malice and bad faith in filing the charge of falsification: The Court found no perversion of truth in respondent Nable's affidavit that would indicate a lack of personal honesty or good moral character. Mabutas admitted he was not physically present at his job as court stenographer on July 3, 1968, as his daily time record indicated, but was instead attending a criminal case in Calapan, Oriental Mindoro. This admission provided a basis for the filing of the criminal case for falsification, as his presence at the Municipal Court was a matter of defense yet to be determined if justified, especially since no subpoena was issued for him to appear there. Regarding respondent Madarang, his explanation was satisfactory, and good faith is presumed. While he may have erred in considering the case within the jurisdiction of the Court of First Instance of Manila, his honest belief that the case was triable in Manila because the falsified daily time record was submitted to the Department of Justice, which exercised administrative supervision over lower courts in Manila, negated malice or bad faith. A mistake on a doubtful or difficult question of law can be the basis of good faith. On the issue of harassment: The Court found that the actions of the respondents did not constitute harassment. Respondent Nable filed the charges in good faith, believing an offense was committed, and abandoned the case before respondent Madarang upon learning of the lack of jurisdiction, refiling it in Oriental Mindoro. Respondent Madarang acted in accordance with official duty, believing in good faith that the case was within his jurisdiction. The Court concluded that the evidence did not warrant disciplinary action against either respondent.
Main Doctrine
An administrative complaint for harassment against public officers will be dismissed if there is no sufficient evidence to overcome the presumption of good faith and if the actions taken were based on an honest belief, even if a mistake in legal interpretation occurred.