Young v. Mapayo

A.M. No. RTJ-00-1552 (May 31, 2000)

Facts:

Marlan Young, an American national residing in Pantukan, Davao, filed an administrative complaint against Judge Hilario I. Mapayo of the Regional Trial Court, Branch 19, Digos, Davao del Sur, on September 2, 1998. The complaint alleged grave misconduct, specifically that Judge Mapayo had solemnized Young's marriage to Virginia Parba on March 15, 1993, and had demanded and received Ten Thousand Pesos (P10,000.00) for the ceremony. Young claimed that Judge Mapayo had asked him and others to sign six blank copies of the marriage contract, which the judge later filled out, indicating June 9, 1993, as the date of the marriage. Young contended that he was out of the country on that date, as evidenced by his passport.

Young further alleged that he sought the judge's assistance in filing for annulment of the marriage, which had been ongoing for two years without resolution. He claimed that during a confrontation with Judge Mapayo and Virginia Parba, they threatened him with deportation, leading him to believe there was a conspiracy against him.

The Ombudsman for Mindanao referred the complaint to the Court Administrator, who subsequently requested comments from Judge Mapayo. In his response, Judge Mapayo denied all allegations and provided an affidavit from Virginia Parba, which contradicted Young's claims. Parba stated that the P10,000.00 was given to her mother for wedding expenses, not to Judge Mapayo, and that she had a good relationship with the judge and his family.

The investigation included requests for Young's travel records from the Bureau of Immigration to verify his claims regarding his presence in the Philippines during the marriage ceremony. The case was eventually referred to Justice Remedios A. Salazar-Fernando for investigation and recommendation.

Legal Issues:

1. Whether Judge Hilario I. Mapayo committed grave misconduct by demanding and receiving P10,000.00 for the solemnization of the marriage.
2. Whether Judge Mapayo falsified the date and place of the marriage of Marlan Young and Virginia Parba.

Arguments:

• Complainant's Arguments:

  • Young asserted that Judge Mapayo demanded a fee for the marriage ceremony, which would constitute illegal exaction.
  • He claimed that the judge falsified the marriage records by changing the date and place of the marriage, which would amount to falsification of a public document.
  • Young provided his travel records to support his claim that he was not in the country on the date indicated in the marriage certificate.

• Respondent's Arguments:

  • Judge Mapayo denied all allegations, asserting that he did not receive any money for the marriage and that the P10,000.00 was given to Virginia Parba's family for wedding expenses.
  • He argued that the evidence presented by Young was insufficient to prove his claims, particularly regarding his travel records, which were deemed unreliable.
  • The judge highlighted that Young had previously acknowledged the validity of the marriage in his annulment petition, which contradicted his current claims.

Court's Decision and Legal Reasoning:

The court dismissed the complaint against Judge Mapayo for lack of merit. It found that the allegations of grave misconduct were not substantiated by credible evidence. The court noted that:

• Young's claim that Judge Mapayo demanded P10,000.00 was not proven, as there was no direct evidence linking the judge to the receipt of the money.
• Virginia Parba's affidavit supported the judge's position, indicating that the money was intended for her family, not for the judge.
• The evidence regarding Young's travel was inconclusive. The Bureau of Immigration records contained discrepancies regarding his identity, and the photocopy of his passport was unreadable and unverified.
• Young's own admission in the annulment petition that the marriage took place on June 9, 1993, undermined his claim that he was out of the country at that time.

The court emphasized that the withdrawal of the complaint by Young did not preclude the court from investigating the matter, as the integrity of the judiciary was of paramount concern.

Significant Legal Principles Established:

1. The court retains jurisdiction over administrative complaints against judges, regardless of the complainant's withdrawal of the complaint.
2. The burden of proof lies with the complainant to establish the allegations of misconduct against a judge.
3. Entries in official records are considered prima facie evidence of the facts stated therein, and discrepancies in evidence can undermine a complainant's claims.