Case Digest (A.M. No. MTJ-92-6-251)
Facts:
The case at hand is an administrative matter involving Judge Emerito M. Agcaoili, the complainant, against Judge Jose O. Ramos, the respondent, who served in the Municipal Trial Court of Echague, Isabela. The administrative complaint stemmed from a letter dated May 13, 1992, from Judge Agcaoili, who was then the Acting Presiding Judge of Regional Trial Court, Branch 9 in Aparri, Cagayan. In this correspondence, Judge Agcaoili reported an inordinate delay in the preliminary investigation of Crim. Case No. 24-0331, initially filed under Crim. Case No. 263, concerning a homicide charge against individuals Jessie Opulencia, Sonny Hernal, and Samuel Lim. Agcaoili also referred to the delays in handling three additional criminal cases pending before Ramos’ sala: Crim. Case Nos. 24-0289, 24-0301, and 24-0311.
In his response, Judge Ramos acknowledged the delays, attributing the inaction primarily to his efforts as a "practicing Christian" to facilitate amicable settlements,
Case Digest (A.M. No. MTJ-92-6-251)
Facts:
- Complainant Judge Emerito M. Agcaoili, serving as Acting Presiding Judge and Acting Executive Judge of the RTC in Echague, Isabela, submitted a letter dated 13 May 1992.
- The letter detailed the inordinate delays by Respondent Judge Jose O. Ramos, of the Municipal Trial Court of Echague, in conducting preliminary investigations in several criminal cases.
Origin of the Administrative Case
- Crim. Case No. 24-0331 (earlier docketed as Crim. Case No. 263) – People v. Jessie Opulencia, Sonny Hernal, and Samuel Lim for Homicide.
- Delay noted in concluding the preliminary investigation.
- Respondent attempted to justify the delay by claiming efforts as a “practicing Christian” to settle the civil aspects amicably.
- Other Criminal Cases Pending in the Sala
- Crim. Case No. 24-0287 – Involved a homicide through reckless imprudence charge against accused Santiago Ayap.
- Preliminary investigation conducted on 20 May 1987 and 6 July 1987; subsequent inaction lasted three years, six months, and thirteen days until 27 December 1990 when a resolution was issued recommending the filing of information.
Cases Involved and Alleged Delays
- Initially, Judge Silvestre H. Bello, Jr. was designated to investigate but recused himself due to a longstanding personal association with Judge Ramos.
- Subsequently, Judge Artemio R. Alivia of RTC Cauayan, Isabela, Branch 19, was appointed, and his report was submitted on 23 April 1993.
Appointment of Investigating Judges
- The original complaint was filed on 5 December 1986, despite Respondent Judge Ramos altering the recorded filing date to 26 October 1987.
- Evidence such as sworn statements and the certification of a stenographic reporter established that the proceedings commenced on 5 December 1986.
- The accused, namely Samuel Lim and Sonny Hernal, were ordered to file their counter-affidavits on separate dates but both failed to comply.
- Respondent’s delay extended until 18 November 1991 when a resolution was issued, with the information eventually filed on 3 April 1992.
- The Investigating Judge found that the delay violated Rule 112 of the Amended Rules on Criminal Procedure.
Detailed Findings in Crim. Case No. 24-0331
- The delays in resolving all four criminal cases were deemed excessive and contrary to the 10-day resolution requirement after concluding a preliminary investigation.
- The unauthorized alteration of the filing date in Crim. Case No. 24-0331 further compounded the misconduct.
- The respondent’s explanations attributing delays to either civic intervention or clerical negligence were rejected as insufficient accountability for his judicial duties.
Implicated Violations and Misconduct
Issue:
- Focus on the violation of Rule 112 of the Amended Rules on Criminal Procedure regarding the timely resolution of preliminary investigations.
Whether Judge Jose O. Ramos committed acts amounting to gross ignorance of the law, dereliction of duty, and serious misconduct by failing to promptly conduct and resolve preliminary investigations.
- Examination of the responsibility of a judge to manage the docket irrespective of administrative shortcomings by subordinate personnel.
Whether the respondent’s justifications—attributing delays to his efforts towards amicable settlements in the civil aspect and clerical negligence by his former Clerk—are tenable grounds to excuse the judicial inaction.
- Whether the alteration of the filing date in Crim. Case No. 24-0331 constitutes falsification of records and, consequently, an aggravating factor that merits harsher disciplinary action.
- Whether the delays in each of the four criminal cases systematically undermined the administration of justice, potentially leading to the loss of evidence and denial of justice to the parties involved.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)