Young v. Mapayo
REITERATIONFacts
The Antecedents: Complainant Marlan Young, an American national, filed an administrative complaint for grave misconduct against Judge Hilario I. Mapayo. The complaint alleged that the respondent judge performed the marriage between complainant and Virginia Parba on March 15, 1993, demanding and receiving P10,000.00 for the ceremony. It was further alleged that the respondent judge had complainant sign blank marriage contract copies and later accomplished them with "Digos" and June 9, 1993, as the place and date of solemnization, respectively, despite complainant allegedly being out of the country on the latter date. Complainant also claimed the respondent judge was part of a conspiracy, as evidenced by threats of deportation during a confrontation. Procedural History: The complaint was referred to the Office of the Ombudsman for Mindanao, then to the Court Administrator, and subsequently to respondent Judge Mapayo for comment. Judge Mapayo denied the allegations and submitted supporting documents, including an affidavit from Virginia Parba and the final decision on an annulment case where complainant acknowledged the marriage's validity. The marriage was later annulled. The Court Administrator requested photocopies of complainant's passport and information from the Bureau of Immigration regarding his travel. The case was eventually referred to an Associate Justice of the Court of Appeals for investigation, report, and recommendation. The Investigating Justice recommended the dismissal of the charges. The Petition: The Supreme Court reviewed the recommendation of the Investigating Justice.
Issue(s)
Whether the respondent judge committed grave misconduct by demanding and receiving P10,000.00 for the solemnization of marriage. Whether the respondent judge committed grave misconduct by falsifying the date and place of the marriage. Whether the withdrawal of the complaint by the complainant warrants dismissal.
Ruling
The Supreme Court dismissed the complaint for grave misconduct against Judge Hilario I. Mapayo for lack of merit. The Court found that the charges were not sufficiently proven.
Ratio Decidendi
On the issue of demanding and receiving P10,000.00: The Court found that the complainant failed to prove that the respondent judge demanded or received the amount. The complainant's statements regarding the money were inconsistent, with one version stating it was given to his ex-wife's aunt and another to the ex-wife's mother for wedding and travel expenses. In the absence of positive evidence directly pointing to the respondent judge as the recipient, this charge must fail. The Court reiterated that the burden of proof rests on the complainant to establish the allegations with substantial evidence. On the issue of falsifying the date and place of marriage: The Court found the evidence presented by the complainant to prove he was out of the country on June 9, 1993, to be of dubious value. The Bureau of Immigration (BI) certification showed discrepancies in the birth dates of the "Marlan W. Young" listed, raising doubts about whether it was the same person. Furthermore, the BI admitted that only records from NAIA and Mactan Airport were computerized, leaving open the possibility of entry through other ports. The photocopy of the passport was unauthenticated and illegible, and the complainant refused to produce the original. Crucially, the complainant himself had previously acknowledged the marriage's validity on June 9, 1993, in his annulment petition, which contradicted his claim of being abroad. Moreover, documents necessary for the marriage, such as the Affidavit in Lieu of Legal Capacity to Contract Marriage and Pre-Marriage Counseling, were dated May 19 and May 25, 1993, respectively, making a March 15, 1993 marriage date impossible. The Court emphasized that entries in official records are prima facie evidence of the facts stated therein. On the issue of withdrawal of the complaint: The Court reiterated its ruling in Marcelino vs. Judge Singson, Jr., stating that mere desistance by the complainant does not warrant the dismissal of administrative complaints against members of the bench. The Court retains its jurisdiction to determine the veracity of the charges and to discipline erring respondents, as the judiciary's integrity is a paramount concern.
Main Doctrine
A withdrawal of an administrative complaint against a member of the bench does not divest the Court of its jurisdiction to determine the veracity of the charges and to discipline the respondent if warranted. The charges must be proven by substantial evidence.