STATE PROSECUTORS v. JUDGE MANUEL T.

MURO
A.M. No. RTJ-92-876
19 September 1994
Aspects of the Proceedings (Sec. 1, Article III)
FACTS:
State Prosecutors, the complainants, filed an administrative case against respondent Judge
Manuel T. Muro on the ground of ignorance of the law, grave misconduct, and violations of the Code
of Judicial Conduct.
The complainants filed the case after respondent Judge dismissed eleven (11) cases submitted
by the state prosecutors against the accused Mrs. Imelda Romualdez Marcos for violation of Central
Bank Foreign Exchange Restrictions, as provided in CB Circular No. 960.
The complainants argued that the judge erroneously dismissed the eleven cases by basing his
Order on a mere newspaper report announcing that the President has lifted foreign exchange
restrictions purportedly repealing CB Circular No. 960. In dismissing the case, the complainants
contended, that the respondent judge violated the prosecutions right to due process, since they were
not even given the opportunity to submit evidence to prove their case.
On the other hand, the respondent judge averred that the Presidents announcement in the
newspaper has effectively repealed CB Circular No. 960 without need of any publication of the
repealing law, because the said announcement was total, absolute, without qualification, and was
immediately effective. This has therefore, as the judge claimed, deprived the court motu proprio of
jurisdiction of the said case, since the complainants raised a violation that was no longer prohibited by
law. And so, respondent judge ruled that the case against Mrs. Imelda Marcos has become moot and
academic.
With this, the complainants pursed the administrative case against the respondent judge.
ISSUE:
Whether or not the State Prosecutors were denied of due process
HELD:
Yes.
The mere fact that the state prosecutors were not given the opportunity to present evidence on
the matter through a written comment or oral argument is an act of blatant disregard of due process by
the respondent judge.
Speedy disposition of cases does not license a judge to exercise abuse of judicial power and
discretion, nor does it justify a deprivation of the prosecutions right to be heard. Whether or not the
judge clearly knew the factual circumstances of the case based on a newspaper report, it was still
imperative that the prosecution be allowed to at least show or prove that it had strong evidence of the
guilt of the accused. To do otherwise would be tantamount to deprivation of the prosecutions right
to due process.
As the Supreme Court rightly stressed, in order that bias may not be imputed to a judge, he
should have the patience and circumspection to give the opposing party a chance to present his
evidence even if he thinks that the oppositor's proofs might not be adequate to overthrow the case for
the other party. A display of petulance and impatience in the conduct of the trial is a norm of conduct
which is inconsistent with the "cold neutrality of an impartial judge."
Prepared by: Conrado I. Andres V of I-D