ARTICLE VIII SECTION 6 CASE 1 OF 3

Maceda vs Vasquez

FACTS:
1. Bonifacio Maceda was a presiding judge of the RTC of Antique and falsified his
certificate of service.
a. Ombudsman took cognizance of the case and ordered that it could not be
referred to the Supreme Court.
2. Maceda filed a petition for certiorari praying that the Ombudsman be restrained from
entertaining the criminal complaint because the Ombudsman has no jurisdiction over
the case.
ISSUES: WON the Ombudsman has jurisdiction over the case for the alleged falsification of the
judge’s certificate of service. NO.

RULING:
1. Investigation of the Ombudsman constitutes an encroachment into the SC’s
constitutional duty of supervision over all inferior courts.
a. Supreme Court has the power of administrative supervision over all courts
and its personnel. (Art. VIII sec. 6 of consti)
b. It is only the SC that can oversee the judges’ and court personnel’s compliance
against them if they commit any violation thereof.
c. Ombudsman can’t justify its investigation of Maceda by citing the powers
granted to it by the constitution.
i. It undermines the independence of the Judiciary.
ii. It runs counter the mandate of the constitution granting the SC
supervisory power of all courts and personnel.
d. Ombudsman should first refer the matter to the court rather than take
cognizance of the case itself.
e. “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 this court for determination whether said
judge or court employee had acted within the scope of their administrative
duties.