Title : MACEDA VS VASQUEZ

Citation : G.R. No. 102781

April 22, 1993.
Ponente : NOCON, J p:
Facts :
Napoleon Abiera of PAO herein respondent filed a complaint before the Office of the
Ombudsman against petitioner RTC Judge Bonifacio Sanz Maceda. Abiera alleged that petitioner
Maceda has falsified his certificate of service by certifying that all civil and criminal cases which have
been submitted for decision for a period of 90 days have been determined and decided on or before
January 31, 1989, when in truth and in fact, petitioner Maceda knew that no decision had been
rendered in 5 civil and 10 criminal cases that have been submitted for decision. Respondent Abiera
alleged that petitioner Maceda falsified his certificates of service for 17 months.

Issues :
Whether or not the investigation made by the Ombudsman constitutes an encroachment into
the Supreme Court s constitutional duty of supervision over all inferior courts

Held :
A judge who falsifies his certificate of service is administratively liable to the SC for serious
misconduct and under Sec. 1, Rule 140 of the Rules of Court, and criminally liable to the State under the
Revised Penal Code for his felonious act.

In the absence of any administrative action taken against him by the 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.

Art. VIII, Sec. 6 of the Constitution exclusively vests in the SC administrative supervision over all
courts and court personnel, from the Presiding Justice of the CA down to the lowest municipal trial court
clerk. By virtue of this power, it is only the SC 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.

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
SC for determination whether said judge or court employee had acted within the scope of their
administrative duties.