CANON 6 OF THE NEW CODE OF JUDICIAL CONDUCT: Competence and Diligence

Canon 6.03 - Judges shall take reasonable steps to maintain and enhance their knowledge, skills and personal qualities necessary for the proper performance of judicial duties, taking advantage for this purpose of the training and other facilities which should be made available, under judicial control, to judges.
CASE # 170: PEOPLE VS. SALAS [G.R. No. 115192. March 7, 2000]
PONENTE: J. Quisumbing FACTS: Elmer Salas (respondent-appellee) was accused of committing robbery with homicide to Virginia S. Talens and was found guilty by the trial court with the circumstantial evidences presented by the prosecution. His main defense was denial, which was found inherently weak by the trial court. Upon appeal, Elmer questioned the basis of the trial courts decision by saying that their decision was based solely on speculation, surmise, and conjecture and that there was no shred of direct evidence that will prove beyond doubt that he committed the crime since it was based only on suspicion and scanty evidence. Upon review by the appellate court, they held the trial courts decision and reaffirmed it by explaining when circumstantial evidence can be considered when direct evidence is lacking. Furthermore, they stated the inherent weakness of Elmers defense by mere denial and relying only on testimonies that are uncorroborated upon cross-examination. Hence, the Court of Appeals followed the same judgment of the trial court. ISSUE: Whether or not the judge in this case appropriately followed Canon 6.03 of the New Code of Judicial Conduct. HELD: Yes. RATIO DECIDENDI: As stated above, both the judge in the trial court and appellate level in this case followed proper competence and diligence when it came to deciding this case since they both came to the same decision with the necessary laws and jurisprudence to prove their points. Not only that, they made sure to explain properly what constitutes a proper application of circumstantial evidence when it comes to deciding criminal cases. Furthermore, they were able to properly determine the values of the evidences presented to them and their respective strengths in court. Therefore, it can be said without doubt that the judges in this case took reasonable steps to maintain and enhance their knowledge, skills, and personal qualities necessary for the proper performance of their judicial duties.