Estrada v. Rural Bank of Binmaley
REITERATIONFacts
The Antecedents: Judge Bienvenido R. Estrada inhibited himself from Civil Case No. SCC-1822 on April 22, 1996, due to his membership in the Board of Directors of the Rural Bank of Labrador, a respondent in the case. Procedural History: The Supreme Court required Judge Estrada to explain why no disciplinary sanction should be imposed for holding the position. Judge Estrada explained that he resigned from the Board of Directors effective May 31, 1997. The Office of the Court Administrator reported that Judge Estrada transferred to the judiciary on May 17, 1994, and failed to comply with Circular No. 6 dated April 10, 1987, which mandates immediate resignation from such positions. The OCA noted that resignation mitigates but does not excuse the liability. The Petition: The case concerns the administrative liability of Judge Estrada for violating Circular No. 6.
Issue(s)
Whether Judge Bienvenido R. Estrada committed an administrative liability for holding a position as a member of the Board of Directors of the Rural Bank of Labrador while being a member of the judiciary. Whether Judge Estrada's subsequent resignation from the Board of Directors excuses his violation of Circular No. 6.
Ruling
Judge Bienvenido R. Estrada is hereby REPRIMANDED with the WARNING that repetition of the same or similar acts for which he is being reprimanded will be dealt with more severely.
Ratio Decidendi
On Whether Judge Bienvenido R. Estrada committed an administrative liability for holding a position as a member of the Board of Directors of the Rural Bank of Labrador while being a member of the judiciary: Yes, Judge Estrada committed an administrative liability. Circular No. 6 dated April 10, 1987, strictly enjoins all Judges not to accept the position of director or any other position in any electric cooperative or other enterprises, or to resign immediately from such position if they are already holding the same. Judge Estrada, who was appointed to the judiciary on May 17, 1994, failed to comply with this directive by not resigning from the Board of Directors of the Rural Bank of Labrador until May 31, 1997. This failure constitutes a violation of the said circular. On Whether Judge Estrada's subsequent resignation from the Board of Directors excuses his violation of Circular No. 6: No, the subsequent resignation does not excuse his violation. The fact that he has already resigned as a Member from the Directorship of the Rural Bank of Labrador does not excuse him from any administrative liability. As a Judge, he should be faithful to the law and maintain professional competence. The present controversy could have been avoided had he kept faith with the injunction that as a member of the bench he must continuously keep himself abreast of legal and jurisprudential developments because the learning process in law never ceases. Assuming without admitting that Judge Estrada acted in good faith and has already resigned, such considerations will simply mitigate his administrative liabilities but will not altogether excuse his ignorance of the law/circulars.
Main Doctrine
A judge's failure to comply with Circular No. 6, which prohibits holding directorships in enterprises, constitutes an administrative liability, even if the judge subsequently resigns from the position. Such resignation may mitigate but does not excuse the violation.