Gross Ignorance of the Law: Judge Fined for Libel Prelim Investigation Without Jurisdiction

A judge's mistake about the reach of his own court's authority is not a minor lapse. In Guyud v. Judge Renato P. Pine (A.M. No. MTJ-03-1469, January 13, 2003), the Supreme Court found a municipal trial court judge guilty of gross ignorance of the law and fined him P5,000 — after he conducted a preliminary investigation in a libel case his sala had no power to handle, and ordered the arrest of the accused in the process.

What happened in the Guyud case

Rolando Guyud and eight other residents of Barangay Gumbaoan, Echague, Isabela, were charged with libel by a fellow resident, Jeffrey Iloreta, over statements contained in a barangay certification.

The complaint was filed before the Municipal Trial Court of Echague, where Judge Renato P. Pine presided. On August 14, 2001, the branch clerk of court issued a subpoena requiring the accused to appear for preliminary investigation. The accused moved to dismiss, arguing that in libel cases only the Office of the Provincial Prosecutor, or