In Dayawon v. Garfin, the Supreme Court emphasized the fundamental right to due process, ruling that a judge cannot convict an accused without conducting a proper trial. The Court found Judge Garfin guilty of gross ignorance of the law for prematurely convicting Fredesminda Dayawon based solely on a hearing for a motion to dismiss, thereby depriving Dayawon of her right to present a full defense. This decision reinforces the principle that procedural shortcuts cannot override an individual’s constitutional right to a fair trial.

Justice Denied: When a Motion to Dismiss Becomes a Conviction

The case revolves around Fredesminda Dayawon, who was charged with violating Batas Pambansa Blg. 22 (BP 22), otherwise known as the Bouncing Checks Law, in four separate criminal cases. After arraignment, Dayawon’s counsel filed a motion to dismiss, arguing that the amounts of the checks had already been paid and that no demands for payment or notices of dishonor were ever made. Judge Zeida Aurora B. Garfin, the presiding judge of the Municipal Trial Court (MTC) of Iriga City, Branch II, set a hearing for the motion and directed Dayawon to present evidence of payment. The prosecution opposed the motion.

Following the presentation of evidence by both parties on the motion to dismiss, Judge Garfin issued a joint judgment on March 19, 1999, denying the motion and simultaneously convicting Dayawon on all four counts. She was sentenced to six months imprisonment for each case and ordered to indemnify the private complainant. This decision was made without setting the cases for a full trial. Dayawon appealed to the Regional Trial Court (RTC) of Iriga City, Branch 34, asserting that the MTC had not conducted a trial. She also filed an administrative case against Judge Garfin with the Office of the Court Administrator (OCA).

Judge Garfin defended her actions, stating that during pre-trial, Dayawon admitted to issuing the checks and initially sought a compromise. According to Judge Garfin, the hearing on the motion to dismiss effectively turned into a full-dress hearing on the merits, with both parties actively participating. She argued that proceeding to a full trial would have been a redundant exercise, causing unnecessary delays. Judge Garfin invoked Section 6, Rule 135 of the Rules of Court, which allows courts to adopt suitable processes when the procedure is not specifically outlined by law or rules. However, the Supreme Court disagreed, emphasizing the importance of due process and adherence to established rules of procedure.

The Supreme Court referenced Section 3(e) of Rule 119 of the then applicable 1985 Rules of Criminal Procedure. This rule, now found in the 2000 Rules of Criminal Procedure as Section 11, Rule 119, provides a modified order of trial when an accused admits the act but raises a lawful defense. The Court clarified that even with such an admission, a trial is still necessary to ascertain the validity of the defense. The pertinent provision states:

SEC. 3. Order of Trial.–

x x x                              x x x                              x x x

(e) However, when the accused admits the act or omission charged in the complaint or information but interposes a lawful defense, the order of trial may be modified accordingly.

The Court explained that even if Dayawon admitted to issuing the checks, a trial was still required to determine if her defense—that the checks had been paid—was valid. Moreover, the Court found that Judge Garfin failed to notify Dayawon that the case would be decided on its merits, depriving her of the opportunity to present additional evidence. The Court stated:

A judge should observe the usual and traditional mode of adjudication requiring that he should hear both sides with patience and understanding to keep the risk of reaching an unjust decision at a minimum.

This lack of due process was a critical factor in the Court’s decision. The Court underscored that procedural shortcuts should not compromise the fundamental rights of the accused. The RTC had already vacated and set aside the MTC’s judgment, remanding the case for further proceedings. The Supreme Court emphasized that there was no indication that Dayawon had consented to submitting the cases for decision without a trial. Participation in the motion to dismiss hearing could not be construed as a waiver of her right to a full trial. The court stated that:

The rules likewise do not sanction the “automatic conversion” of a hearing on a motion to dismiss to a hearing on the merits of a case, in the absence of any clear waiver by the accused of his right to a regular trial.

The Supreme Court concluded that Judge Garfin’s actions constituted gross ignorance of the law. While there was no evidence of malice or bad faith, the Court held that ignorance of basic procedural rules is inexcusable for a judge. However, the Court did not find Judge Garfin guilty of gross misconduct, as misconduct requires malice or wrongful intent. The Court noted the difference between a mere error of judgment and a blatant disregard for established rules.

The Court acknowledged that judges may not be disciplined for errors of judgment unless there is a conscious intent to cause injustice. However, judges are still expected to exercise propriety, discretion, and due care in performing their duties. Observing the law is paramount for every judge, and ignorance of basic legal principles constitutes gross ignorance of the law.

FAQs

What was the central issue in this case?	The key issue was whether Judge Garfin violated Dayawon’s right to due process by convicting her without a proper trial, based solely on the hearing for a motion to dismiss.
What is Batas Pambansa Blg. 22?	Batas Pambansa Blg. 22, also known as the Bouncing Checks Law, penalizes the issuance of checks without sufficient funds or credit.
What was the basis for the motion to dismiss?	The motion to dismiss was based on the argument that the amounts of the bounced checks had already been paid and that Dayawon had not received any demand letters or notices of dishonor.
Did Dayawon admit to issuing the checks?	According to Judge Garfin, Dayawon admitted to issuing the checks during the pre-trial proceedings, initially seeking a compromise.
Why did the RTC set aside the MTC’s judgment?	The RTC set aside the MTC’s judgment because Dayawon was convicted without a full trial, violating her right to due process.
What is gross ignorance of the law?	Gross ignorance of the law refers to a judge’s inexcusable lack of knowledge or disregard of basic legal principles, which they are expected to know and apply.
Was Judge Garfin found to have acted maliciously?	No, the Supreme Court found no evidence of malice or wrongful intent on Judge Garfin’s part, distinguishing her actions from gross misconduct.
What was the Supreme Court’s ruling?	The Supreme Court found Judge Garfin guilty of gross ignorance of the law and ordered her to pay a fine of P10,000.00, with a stern warning against future similar acts.

The Dayawon v. Garfin case serves as a crucial reminder of the judiciary’s duty to uphold due process and ensure fair trials. It clarifies that procedural efficiency cannot justify sacrificing an individual’s fundamental rights. By emphasizing adherence to established rules and procedures, the Supreme Court reinforced the integrity of the Philippine legal system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

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: FREDESMINDA DAYAWON VS. JUDGE ZEIDA AURORA B. GARFIN, A.M. No. MTJ-01-1367, September 05, 2002