**Facts:**
1. On August 23, 1994, Emeterio Gallo filed a criminal complaint against Cristuto Barreta, Alberto Macabata, Danilo Morillo, and Rodolfo Villanueva for violating P.D. No. 772 (Anti-Squatting Law) in the Municipal Trial Court (MTC) of Babatñgon, Leyte under Judge Jose Cordero.
2. The complaint alleged that the accused occupied and possessed property owned by Gallo in Barangay Bagong Silang without consent and refused to vacate despite demands.
3. On August 26, 1994, Judge Cordero issued a subpoena to Gallo, requiring his appearance with ownership documents. Gallo appeared on August 30, 1994, without the documents but later provided a certified tax declaration when requested by the judge.
4. Gallo inquired about the arrest of the accused, and the judge explained that the law prevents tenants’ eviction, though Gallo argued the accused were not tenants.
5. Gallo’s son, Roger, later observed the accused in a private discussion with the judge when delivering a letter from Gallo inquiring about arrest warrants.
6. Gallo accused Judge Cordero of delaying justice, bias, and ignorance of law, claiming Cordero refused to issue arrest warrants, conversed privately with the accused, and made prejudicial statements.
7. Gallo petitioned for Cordero’s suspension or inhibition and eventual dismissal from service.
8. Judge Cordero contended the complaint didn’t invoke P.D. No. 772 as it lacked specifics about urban status and also lacked vital complaint details like time and offended party. He also referenced Administrative Circular No. 8-92, expressing concerns about potential jurisdictional conflict with agrarian reform cases.
9. He denied bias, asserting discussions with the accused were to advise them of free legal counsel options.
**Issues:**
1. Did Judge Cordero improperly refuse to issue warrants for the accused in Criminal Case No. 2194?
2. Was Judge Cordero guilty of bias or manifest partiality based on his interactions with the accused?
3. Did Judge Cordero demonstrate gross ignorance of the law in his handling of the criminal complaint?
**Court’s Decision:**
1. **Refusal to Issue Warrants:** The Court opined that Judge Cordero exhibited confusion and inadequate action when he neither dismissed the complaint nor issued warrants. He misapplied legal standards since the non-dismissal implied adequate grounds for trial. His actions reflected gross ignorance as guided by Rule 112 regarding the issuance of warrants.
2. **Bias and Partiality:** Judge Cordero’s private meetings with the accused without complainant’s presence, merely for advising them on free legal counsel, were deemed improper and violated judicial impartiality norms. This was contrary to the Code of Judicial Conduct expecting judges to avoid impropriety and promote public confidence in the judiciary.
3. **Ignorance of Law:** The judge exhibited incorrect legal reasoning regarding land classification under P.D. No. 772, as current jurisprudence did not confine offenses to urban areas only.
**Doctrine:**
1. **Judicial Impartiality:** Judges should avoid both impropriety and its appearance, maintaining transparency and fairness to preserve public trust.
2. **Proper Adjudicative Actions:** Judges must correctly apply procedural and substantive standards, securing or dismissing complaints based on field truth and legal compliance (Rule 112 of Revised Rules on Criminal Procedure).
**Class Notes:**
– **Judicial Conduct:** Articulated under Canons requiring avoidance of bias and maintaining public confidence in judicial impartiality.
– **Preliminary Procedures:** Rule 112 requires diligent evaluation of evidence to either dismiss cases or enforce warrants based on establishment of trial grounds.
**Historical Context:**
The case reflects judicial struggles and accountability concerns amid rapid legal transformations during post-Martial Law governance. It also highlights the ongoing discourse on judicial ethics and land-related legislative overlap in rural and agrarian settings in the Philippines. The decision addressed procedural lapses and sustained a discourse on housing regulations within evolving urban-rural legal interpretations.
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