Dayot v. Garcia
"REITERATION"Facts
1. The Antecedents: Complainant Sofronio Dayot was convicted of Grave Slander by respondent Judge Rodolfo Garcia. The initial sentence imposed by the Municipal Circuit Trial Court was imprisonment of one (1) month and one (1) day to four (4) months of arresto mayor, along with attorney's fees and exemplary damages. This conviction and sentence were affirmed by the Regional Trial Court, which also increased the penalty to three (3) months of arresto mayor as a minimum to one (1) year and one (1) day of prision correccional as a maximum, and increased the moral damages awarded. 2. Procedural History: Following the affirmation by the Regional Trial Court, the complainant filed a petition for review with the Court of Appeals, which dismissed the petition. A subsequent Motion for Reconsideration was also denied. The case was then elevated to the Supreme Court via a petition for review on certiorari, docketed as G.R. No. 132446. This petition was initially denied due course by the Court's Second Division. A Motion for Reconsideration of this denial was pending when the respondent judge issued a warrant for the complainant's arrest and ordered his detention. The Supreme Court subsequently denied the motion for reconsideration with finality. 3. The Petition: The complainant initiated the present administrative case, alleging misconduct, abuse of authority, and oppression by the respondent judge. Specifically, the complainant contended that the judge improperly issued a warrant of arrest and ordered detention while a motion for reconsideration was pending before the Supreme Court. Furthermore, the complainant alleged that a motion to lift the arrest warrant remained unacted upon and that the judge issued an order discrediting his service of sentence without due process or a hearing. The Court Administrator recommended a fine for the judge, finding that the order discrediting the service of sentence was issued without a hearing or notice to the accused.
Issue(s)
Whether the respondent Judge committed administrative misconduct and oppression by issuing a warrant of arrest pending a motion for reconsideration and allegedly failing to act on a motion to lift said warrant. Whether the respondent Judge violated the complainant's right to due process by unilaterally issuing an order discrediting the complainant's service of sentence without a hearing.
Ruling
"Respondent Judge Rodolfo B. Garcia is FINED P5,000.00, with a stern warning that a repetition of the same or similar act will be dealt with more severely. The charges regarding the issuance of the arrest warrant and the alleged failure to act on the motion to lift were not administratively sustained."
Ratio Decidendi
Regarding the issuance of the warrant and the motion to lift it, the Court found the charges untenable and inappropriate for an administrative proceeding. The Court noted that the respondent Judge did not fail to act, as he had actually issued an Order denying the motion to lift the warrant on June 25, 1998. Furthermore, the Court held that determining whether the Judge correctly denied the motion is a judicial matter, which cannot be the subject of an administrative complaint unless the error is tainted with fraud, dishonesty, or bad faith. Regarding the discrediting of the service of sentence, the Court ruled that the respondent Judge failed to observe the requirements of due process. The Judge issued the order based solely on an oral complaint that the accused was not in a prison cell, without providing the accused or his counsel any notice or opportunity to be heard. Citing De Vera vs. Dames II, the Court emphasized that judicial immunity is not a license to be abusive or arbitrary, and applying Macasasa vs. Imbing, the Court declared that issuing an order without a hearing betrays ignorance of the cardinal principles of due process.
Main Doctrine
"A judge who summarily discredits a convict\u2019s service of sentence without notice and hearing violates due process and may be administratively sanctioned; administrative proceedings are not substitutes for judicial remedies to correct alleged judicial errors."