Maceda v.

Vasquez
G.R. No. 102781. April 22, 1993.
Nocon, J.

whether the Office of the Ombudsman could entertain a criminal complaint for the alleged
falsification of a judges certification submitted to the Supreme Court, and assuming that it can, whether
a referral should be made first to the Supreme Court

Facts:

Held:

Petitioner Bonifacio Sanz Maceda, Presiding Judge of Branch 12 of the Regional Trial Court
of Antique, seeks the review of the following orders of the Office of the Ombudsman: (1) the Order
dated September 18, 1991 denying the ex-parte motion to refer to the Supreme Court filed by petitioner;
and (2) the Order dated November 22, 1951 denying petitioners motion for reconsideration and
directing petitioner to file his counter-affidavit and other controverting evidences.

In the absence of any administrative action taken against him by the Supreme Court with
regard to his certificates of service, the investigation being conducted by the Ombudsman encroaches
into the Courts power of administrative supervision over all courts and its personnel, in violation of the
doctrine of separation of powers.

In his affidavit-complaint dated April 18, 1991 filed before the Office of the Ombudsman,
respondent Napoleon A. Abiera of the Public Attorneys Office alleged that petitioner had falsified his
Certificate of Service 1 dated February 6, 1989, by certifying that all civil and criminal cases which
have been submitted for decision or determination for a period of 90 days have been determined and
decided on or before January 31, 1998, when in truth and in fact, petitioner knew that no decision had
been rendered in five (5) civil and ten (10) criminal cases that have been submitted for decision.
Respondent Abiera further alleged that petitioner similarly falsified his certificates of service for the
months of February, April, May, June, July and August, all in 1989; and the months beginning January
up to September 1990, or for a total of seventeen (17) months.

On the other hand, petitioner contends that he had been granted by the Supreme Court an
extension of ninety (90) days to decide the aforementioned cases.

Issue:

Article VIII, section 6 of the 1987 Constitution exclusively vests in the Supreme Court
administrative supervision over all courts and court personnel, from the Presiding Justice of the Court of
Appeals down to the lowest municipal trial court clerk. By virtue of this power, it is only the Supreme
Court that can oversee the judges and court personnels compliance with all laws, and take the proper
administrative action against them if they commit any violation thereof. No other branch of government
may intrude into this power, without running afoul of the doctrine of separation of powers.

Thus, the Ombudsman should first refer the matter of petitioners certificates of service to the
Supreme Court for determination of whether said certificates reflected the true status of his pending case
load, as the Supreme Court has the necessary records to make such a determination. The Ombudsman
cannot compel the Supreme Court, as one of the three branches of government, to submit its records, or
to allow its personnel to testify on this matter, as suggested by public respondent Abiera in his affidavitcomplaint.

In fine, where a criminal complaint against a Judge or other court employee arises from their
administrative duties, the Ombudsman must defer action on said complaint and refer the same to the

Supreme Court for determination whether said Judge or court employee had acted within the scope of
their administrative duties.

www.uberdigests.info/2014/0
9/garcia-vs-macaraig/2/

Sep 3, 2014
- READ CASE
DIGEST HERE. .... For
in Manila Electric
Co. vs. Pasay
TransportationCo., 13 me
ntioned therein, Justice
Malcolm , speaking for ...

G.R. No. 161957/G.R.

No. 167994. January
22, 2007
sc.judiciary.gov.ph/jurispruden
ce/2007/jan2007/161957.htm

highlighted in
the cases of Manila
Electric Co. v. Pasay
Trans. Co.[44] and ...

Law & Society by

Chester Cabalza:
Manila Electric
Company vs. NLRC
cbclawmatters.blogspot.com/
2010/07/manila-electriccompany-vs-nlrc.html

Jul 13, 2010 - Private

respondent Signo was
employed in petitioner
company as ... within the
serviceable point
of Meralco, because the
place was beyond the 30meter ...
commentaries, case
digests (recommends
reading the full &
original ...
[PDF]ADMINISTRATIVE

167994 is a Rule 65
petition filed on 6 May
2005, or while the
motions for ..... This was

LAW CASE DIGESTS

docshare01.docshare.tips/file
s/27574/275747223.pdf

Law's Cool.: Civil Code

Digested Cases
ADMINISTRATIVE
LAW CASE DIGESTS ...
to the case at hand, reads
as follows: ..... Manila
Electric Company
v. Pasay. Transportation
Company, Inc.,. Facts:.

writ of kalikasan Harry Roque

www.harryroque.com/tag/writof-kalikasan/

Mar 15, 2016 - First ever

Writ of Kalikasan filed in
CA vs. ... The residents of
Barangay 183 in
Villamor, Pasay City and
Magallanes Village in
Makati ....
Respondent MANILA
ELECTRIC
COMPANY(MERALCO)
is a domestic corporation
created .... [9] In the
instant case, the high
tensiontransmission line
s being erected by ...

cj-says-law-iscool.blogspot.com/2010/09/pe
rsons-and-familyrelations.html

Sep 27, 2010 - (1)

Whether or not all laws
shall be published in the
official gazette .... during
the investigations of
Tobias transgress the
standards of human
conduct set ..... of
the trial court is set aside,
the complaint against
MERALCO is dismissed,
and ....
Regional Trial Court of
the National Capital
Region Pasay City and ...

PHILIPPINE
FISHERIES
DEVELOPMENT
AUTHORITY vs.
CENTRAL ...
www.batasnatin.com/.../1927philippine-fisheries-

development-authority-vscentral-b...

... Insurance
Transportation Laws
Credit Transactions
Case Digests ... in
MIAA vs. Pasay (April 2,
2009) where the property
in question was the airport
premises. In those cases,
the Court additionally
provided that other
examples of
government ...
PROVINCE OF QUEZON
- Real Property Tax
MANILA ELECTRIC
CO. V.

Ateneo Law School

2013 Block B - Yahoo
Groups
https://beta.groups.yahoo.co
m/neo/groups/als2013b/conve
rsations/messages/1036

Jan 31, 2010 - Janna,

thanks for the cases. il do
the digest for: ... MANILA
ELECTRIC COMPANY,
petitioner, vs. PASAY
TRANSPORTATION CO
MPANY.

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