Case Digest (A.M. No. MTJ-91-560)
Facts:
The case involves Francisco Ancheta as the complainant and Judge Pedro C. Antonio as the respondent. The complaint was filed on July 16, 1991, against Judge Antonio, who was the Presiding Judge of the 10th Municipal Circuit Trial Court in Roxas-Quirino, Isabela. The complaint stemmed from Civil Case No. 737, entitled "Francisco Ancheta vs. Dominator Lamorena, et al.," concerning a forcible entry with a preliminary injunction. Ancheta alleged that after the case was submitted for decision in July 1988, Judge Antonio, through an emissary, demanded P10,000.00 in exchange for a favorable ruling. Ancheta claimed that due to his refusal to comply with this demand, the case remained undecided for over three years. In response, Judge Antonio denied the allegations, asserting that they were fabricated by Ancheta's lawyer, Atty. Felipe Bugarin, who allegedly harbored a personal grudge against him.
To support his defense, Judge Antonio submitted an affidavit from Anchet...
Case Digest (A.M. No. MTJ-91-560)
Facts:
- Complaint Filed: Francisco Ancheta filed a sworn complaint on July 16, 1991, against Judge Pedro C. Antonio, Presiding Judge of the 10th Municipal Circuit Trial Court in Roxas-Quirino, Isabela. The complaint alleged "Grave Misconduct and Dereliction of Duty" in relation to Civil Case No. 737, a Forcible Entry case with Preliminary Injunction.
- Allegation of Bribery: Ancheta claimed that after the case was submitted for decision in July 1988, Judge Antonio, through an emissary, demanded P10,000.00 in exchange for a favorable decision. Ancheta refused, and the case remained undecided for over three years.
- Respondent's Defense: Judge Antonio denied the bribery allegation, stating that the complaint was fabricated by Atty. Felipe Bugarin, Ancheta's counsel, who allegedly had a personal grudge against him. He submitted an affidavit from Ancheta dated February 3, 1992, where Ancheta retracted the bribery claim, stating that he was misled by Atty. Bugarin.
- Delay in Case Resolution: Judge Antonio attributed the delay in deciding Civil Case No. 737 to the parties' failure to settle amicably and the emergence of ownership issues, which he claimed took the case out of the summary procedure rules.
- Investigation Findings: Executive Judge Teodulo B. Mirasol investigated the case and found that the Forcible Entry case was filed on June 1, 1987, and dismissed motu proprio by Judge Antonio on October 18, 1991, after being pending for over four years. The case was deemed submitted for decision in September 1988 but was reopened on August 3, 1991, on the flimsy ground of a missing preliminary conference order. Judge Mirasol concluded that Judge Antonio was guilty of willful neglect and undue delay.
Issue:
- Whether Judge Pedro C. Antonio committed attempted bribery by demanding P10,000.00 from Francisco Ancheta in exchange for a favorable decision.
- Whether Judge Antonio unreasonably delayed the disposition of Civil Case No. 737, violating the rules on summary procedure and judicial conduct.
Ruling:
The Supreme Court found Judge Pedro C. Antonio guilty of undue delay in deciding Civil Case No. 737. The Court agreed with the findings of Executive Judge Mirasol that Judge Antonio's actions constituted willful neglect and gross inefficiency. However, the Court did not find sufficient evidence to support the bribery allegation.
Ratio:
- Delay in Case Disposition: Failure to decide a case within the required period constitutes gross inefficiency and violates Rule 3.01 and Rule 3.05 of the Code of Judicial Conduct, which require judges to maintain professional competence and dispose of court business promptly.
- Bribery Allegation: The retraction by Francisco Ancheta in his February 3, 1992 affidavit, coupled with the lack of corroborating evidence, led the Court to conclude that the bribery charge was unsubstantiated.
- Sanction: Judge Antonio was ordered to pay a fine of Ten Thousand Pesos (P10,000.00) for his undue delay in deciding the case, with a stern warning that future similar misconduct would be dealt with more severely.