Maceda vs. Vasquez G.R. No. 102781, April 22, 1993

Facts: Respondent Napoleon Abiera of PAO filed a complaint before the Office of the Ombudsman against petitioner RTC Judge Bonifacio Sanz Maceda. Respondent 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.


Issue: Whether or not the investigation made by the Ombudsman constitutes an encroachment into the SC’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 Court’s 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 personnel’s 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.