This case emphasizes the critical importance of judicial impartiality in the Philippine legal system. The Supreme Court found Judge Marivic Trabajo-Daray guilty of manifest partiality and bias for actions favoring certain parties in multiple cases, including granting a motion to lift a hold departure order without proper notice and failing to resolve pending motions promptly. This decision underscores that judges must not only be impartial but also appear impartial, ensuring public confidence in the integrity of the judiciary. By highlighting the consequences of biased conduct, the ruling reinforces the standards expected of judges to maintain fairness and equity in legal proceedings.

When Haste Undermines Justice: The Erosion of Impartiality in the Courtroom

The administrative complaint against Judge Marivic Trabajo-Daray arose from concerns regarding her conduct in Criminal Case No. 13280, involving estafa through falsification of a public document. State Prosecutor Pablo Formaran III, Atty. Felino M. Ganal, and Kanemitsu Yamaoka alleged that Judge Daray exhibited patent injustice, partiality, and gross ignorance of the law. These accusations stemmed from her handling of the case, particularly concerning actions taken while another judge was on leave. The core issue revolved around whether Judge Daray’s actions compromised the impartiality expected of a member of the bench.

The complainants specifically pointed to an instance where Judge Daray, acting as Pairing Judge for Judge Lubao, who was on leave, granted accused Richard Friend permission to travel to the United States. This decision was made despite pending motions and without proper notice to the opposing parties. The complainants argued that this action was prejudicial and demonstrated a lack of due process. They also raised concerns about the failure to institute safeguards ensuring Friend’s return to the Philippines, given his residency in the United States. The charges were further compounded by allegations related to other cases involving the same parties, suggesting a pattern of bias.

In response, Judge Daray defended her actions, asserting that she acted within her judicial functions as Pairing Judge. She stated that she carefully reviewed the case records and made her decision based on the urgency of the situation, particularly the medical needs of Friend’s son. She also denied any intent to violate the law or the rules of procedure. However, the Supreme Court scrutinized these justifications in light of the procedural lapses and the overall context of the case.

The Supreme Court emphasized the importance of resolving pending motions, particularly a motion for inhibition, before making substantive decisions. They cited respondent judge’s act of ignoring the motion for inhibition as suspect in the light of her previous act of denying Yamaoka’s first and only extension of time to file appellee’s brief but granting a similar motion for extension to the accused. Moreover, the Court took note of the haste with which she had handled the criminal cases in favor of Kawai and Friend.

Central to the Court’s reasoning was the violation of procedural rules, specifically Section 4, Rule 15 of the Rules of Court, which requires that motions be set for hearing, especially if they are litigious and may prejudice the rights of the adverse party. The Court reiterated that a motion without notice of hearing is considered a mere scrap of paper, presenting no question for the court to decide. The lack of proper notice in granting Friend’s motion to travel was a significant factor in the Court’s finding of partiality. This departure from established procedure raised serious concerns about the integrity of the judicial process.

The Court cited Balagtas v. Sarmiento to emphasize the importance of due process and adherence to procedural rules. It declared the respondent judge violated a basic and fundamental constitutional principle, due process. It explained, “When the law is elementary, not to be aware of it constitutes gross ignorance thereof…Hence, the respondent judge is guilty of gross ignorance of the law.”

Ultimately, the Supreme Court adopted the findings of the investigating Justice, concluding that Judge Daray exhibited manifest partiality and bias, violating Rule 2.0.1 of the Code of Judicial Conduct. While the recommended fine was reduced to P20,000.00, the Court sternly warned against any future repetition of similar actions. This decision highlights the judiciary’s commitment to upholding the principles of fairness, impartiality, and due process, ensuring that judges perform their duties with the highest standards of ethical conduct. It underscores the need for judges not only to be just but also to appear just, maintaining public confidence in the legal system.

FAQs

What was the key issue in this case?	The key issue was whether Judge Marivic Trabajo-Daray exhibited partiality and bias in her handling of Criminal Case No. 13280 and related cases. Specifically, the court examined whether her actions compromised the impartiality expected of a member of the judiciary.
What specific actions were questioned?	The questioned actions included granting a motion to lift a hold departure order without proper notice to the opposing parties. Also, the failure to resolve pending motions promptly in other related cases were taken into account.
What did the Supreme Court decide?	The Supreme Court found Judge Daray guilty of manifest partiality and bias. It penalized her with a fine of P20,000.00, with a stern warning against any future repetition of similar actions.
What is Rule 2.0.1 of the Code of Judicial Conduct?	Rule 2.0.1 of the Code of Judicial Conduct enjoins judges to behave at all times in a manner that promotes public confidence in the integrity and impartiality of the judiciary. The point is to promote integrity and impartiality of the judicial system.
Why was granting the motion to lift the hold departure order considered partial?	Granting the motion to lift the hold departure order was deemed partial because it was done without proper notice to the opposing parties, violating established procedural rules and raising concerns about due process. This departure undermined procedural integrity.
What is the significance of the Balagtas v. Sarmiento case?	Balagtas v. Sarmiento reinforces the principle that a motion without notice of hearing is a mere scrap of paper and that granting such motions violates due process. Judges must always exercise extra caution when resolving procedural issues.
What is the role of an Investigating Justice in this case?	The Investigating Justice, in this case from the Court of Appeals, reviewed the complaints against Judge Daray, gathered evidence, and made a recommendation to the Supreme Court based on her findings. It’s to ensure facts are carefully evaluated.
What practical lesson can judges and lawyers learn from this case?	The practical lesson is that judges must not only be impartial but also appear to be impartial, adhering strictly to procedural rules and ensuring due process for all parties involved. The goal is fairness above all else.

This case serves as a critical reminder to judges and legal professionals alike of the paramount importance of maintaining impartiality and adhering to established legal procedures. The Supreme Court’s decision reinforces the principle that justice must not only be done but also be seen to be done, fostering trust and confidence in the legal system.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: STATE PROSECUTOR PABLO FORMARAN III, ET AL. VS. JUDGE MARIVIC TRABAJO-DARAY, A.M. No. RTJ-04-1885, November 17, 2004