De Asis v. Doronila
REITERATIONFacts
The Antecedents: On September 3, 2002, Administrative Order No. 128-2002 (AO 128-2002) was issued, designating Judge Ronaldo P. Melliza, Jr. as Assisting Judge of the Municipal Circuit Trial Court of Jordan-Buenavista-Nueva Valencia, Guimaras (MCTC-Guimaras) and directing him to try and decide newly filed cases. Respondent Judge Arturo G. Doronila was directed to try and decide pending cases. Procedural History: On February 7, 2003, a criminal case for Arson (Criminal Case No. 6024-B) was filed against Atty. Vicente B. De Asis before the MCTC-Guimaras. Respondent Judge Doronila conducted a preliminary examination and issued a warrant of arrest against De Asis. The Petition: Atty. De Asis filed an administrative complaint against Judge Doronila, alleging that the latter acted without authority and with grave abuse of discretion amounting to lack or excess of jurisdiction in hearing the criminal case and issuing the warrant of arrest, in violation of AO 128-2002. Judge Doronila argued that he acted on the new cases due to Judge Melliza's inability to act as Assisting Judge and the absence of a substitute, and that he could be subjected to administrative complaints if he did not act on new cases. De Asis countered that there was no immediate need for the preliminary investigation and warrant issuance. The Office of the Court Administrator (OCA) recommended a fine of P5,000.00 for a less serious charge.
Issue(s)
Whether respondent Judge Doronila acted without authority and with grave abuse of discretion amounting to lack or excess of jurisdiction in hearing Criminal Case No. 6024-B and issuing the warrant of arrest in violation of AO 128-2002. Whether respondent Judge Doronila committed a less serious charge by violating Supreme Court rules, directives, and circulars.
Ruling
The Court found respondent Judge Doronila GUILTY of violation of Supreme Court rules, directives and circulars, classified as a less serious charge. He was FINED Fifteen Thousand Pesos (P15,000.00) with a warning that a similar infraction in the future will merit a more severe penalty.
Ratio Decidendi
On the issue of whether respondent Judge Doronila acted without authority and with grave abuse of discretion amounting to lack or excess of jurisdiction in hearing Criminal Case No. 6024-B and issuing the warrant of arrest in violation of AO 128-2002: The Court agreed with the OCA that respondent Judge Doronila was not authorized to try and decide Criminal Case No. 6024-B. Administrative Order No. 128-2002 clearly designated Judge Melliza to try and decide the criminal case, which was a newly filed case. Respondent Judge Doronila was aware of this administrative order but proceeded to hear the case and issue the warrant of arrest, thereby defying the Court's directive. The fact that Judge Melliza reported for work only on specific dates, or that Executive Judge Tito Gustilo issued a memorandum order designating Judge Melliza as acting presiding judge of another court, did not revoke Judge Melliza's designation as Assisting Judge of MCTC-Guimaras. Respondent Judge Doronila should have referred the matter to his executive judge for appropriate action instead of unilaterally acting on the case. His actions constituted a clear violation of a Supreme Court directive. On the issue of whether respondent Judge Doronila committed a less serious charge by violating Supreme Court rules, directives and circulars: The Court held that respondent Judge Doronila's failure to recognize and follow the Court's circular was not merely a grave abuse of authority amounting to grave misconduct or conduct prejudicial to the best interest of the service. Such failure was characterized as disrespect for and a willful violation of a lawful circular of the highest court of the land, to which respondent Judge Doronila owed obedience. Judges are expected to respect orders and decisions of the Supreme Court, and willful non-compliance with court orders and circulars constitutes serious misconduct. Therefore, the violation was classified as a less serious charge under Rule 140, as amended by A.M. No. 01-8-10-SC, which is punishable by a fine or suspension.
Main Doctrine
A judge who violates a clear and simple directive from the Supreme Court, such as an administrative order designating another judge to handle newly filed cases, commits a less serious charge punishable by fine or suspension, demonstrating disrespect for and willful violation of a lawful circular of the highest court.