Case Digest: OFFICE OF THE COURT ADMINISTRATOR V. JUDGE MATAS AND EDUARDO TORRES

OFFICE OF THE COURT ADMINISTRATOR V. JUDGE MATAS AND EDUARDO TORRES

FACTS:

Judge Jesus Matas and Eduardo Torres, the OIC Clerk of Court, were accused of violating RA 3019 which caused then Deputy Court Administrator Ernani Cruz Pano to recommend that the Office of the Court Administrator (OCA) to file administrative charges against the two but said charges will be suspended pending the out come of the criminal case. The complaint alleged that Judge Matas and Torres, in connivance with one George Mercado, concealed from J.K. Mercado and Sons Agricultural Enterprises his knowledge of the petition for issuance of new owner’s duplicate copies as well as taking cognizance of the case which was allegedly outside of the jurisdiction of his court, the land being in Kapalong, Davao. Notwithstanding that the land in question was owned by J.K. Mercado and Sons, Judge Matas still ordered the posing of the order and ultimately issued instructed the Register of Deeds for the issuance a new owner’s duplicate to George Mercado. Justice Imperial was tasked with the investigations. Hearing with the OCA commence but after presenting two witnesses, it moved for suspension of the proceedings to amend the complaint adding the grounds of gross inexcusable negligence and gross ignorance of the law as well as modifying other portions of the complaint. The complaint alleged that Judge Matas and Torres acted with bad faith and partiality in ruling in favour of George Mercado.

ISSUE

1. Whether or not Judge Matas acted without jurisdiction in taking cognizance of the case?

2. Whether or not Judge Matas acted with gross inexcusable negligence and gross ignorance of the law in ruling in favor of George Mercado?

HELD

1. NO. The subject parcel of land was well within the jurisdiction of the court of Judge Matas. The so-called municipality of Sto Tomas in Davao never legally existed because it was created only by then President Carlos P. Garcia and not by Congress. The land was actually part of Kapalong which is within the coverage of Branch 1 of the RTC of Davao del Norte where Judge Matas sits. It was a mere impropriety of venue which may be waived by the parties.
2. NO. There was no gross inexcusable negligence and gross ignorance of the law given that Judge Matas actually ordered the required posting to give notice. Also, he only ordered the RD to issue a duplicate of copy existing in record of the Registry and not issue new ones in the name of George Mercado.
SIDE ISSUE WHICH SEEM TO BE RELATED TO ADMIN LAW: The SC said that the investigating Justice or Judge designated by the Court to Conduct an investigation, submit a report, and make the appropriate recommendation does not have an authority to grant or deny a motion to dismiss the case.
Also, the initial recommendation of the Court Administrator regarding the suspension of the administrative proceedings pending the criminal case is inappropriate since administrative cases must be resolved as expeditiously as possible. There are different quantum of evidence, procedure to be followed and sanctions imposed, hence, the finding of one shouldn’t be necessarily binding on the other.