Title
Avilla vs. Reyes, Jr.
Case
A.M. No. 01-34-CA-J
Decision Date
Jan 23, 2006
PNPA cadets filed mandamus over hazing-related suspensions; CA delay deemed reasonable due to collegiate review, no judicial misconduct found.
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Case Digest (A.M. No. 01-34-CA-J)

Facts:

  1. Case Background: Complainants, members of Class 2001 and Class 2002 of the Philippine National Police Academy (PNPA), filed a petition for Mandamus with Damages before the Court of Appeals (CA). They sought to challenge the suspension, dismissal, and other disciplinary actions imposed on them following the death of Cadet Dominante Tunac, allegedly due to hazing activities prohibited by the school. They argued that the disciplinary actions jeopardized their studies and graduation.

  2. Procedural History: The petition was filed on September 19, 2000, and raffled to the Second Division of the CA on September 20, 2000, with Justice Andres B. Reyes, Jr. as the ponente. Complainants alleged that Justice Reyes failed to act on their petition with dispatch, despite its urgency.

  3. Complainants’ Allegations:

    • On November 6, 2000, oral arguments were held after complainants filed a motion to set the case for oral arguments.
    • Comments were required from the Office of the Solicitor General only on November 7, 2000.
    • Complainants filed a Reiterative Motion on December 14, 2000, urging the issuance of a temporary restraining order (TRO) or writ of mandatory injunction.
    • Due to further inaction, complainants filed a Motion for Inhibition against Justice Reyes on January 3, 2001, which he granted on January 19, 2001.
  4. Respondent’s Defense:

    • Justice Reyes claimed he acted promptly, studying the case upon receipt and identifying technical defects in the petition.
    • He prepared a draft decision by November 27, 2000, which was circulated to other justices for review.
    • Any delay was attributed to the collegiate nature of the CA’s decision-making process, including the inhibition of a justice and the need for a replacement.
  5. Key Evidence:

    • Complainants argued that the draft decision was prepared only after oral arguments and lacked credibility.
    • Justice Reyes submitted a copy of the draft decision and a marginal note from another justice supporting his claim.

Issue:

  1. Whether Justice Andres B. Reyes, Jr. violated Rule 1.02 of Canon 1 of the Code of Judicial Conduct by failing to resolve the petition with dispatch.
  2. Whether the delay in resolving the petition was reasonable under the circumstances.

Ruling:

The Supreme Court dismissed the complaint against Justice Reyes for lack of merit. It found no evidence of bad faith or unreasonable delay in his actions. The Court held that the delay was attributable to the CA’s internal procedures, including the review of the draft decision by other justices and the inhibition of a justice.

Ratio:

  1. Reasonableness of Delay: The Court emphasized that the right to a speedy disposition of cases is relative and flexible. Factors such as the length of delay, reasons for the delay, and prejudice caused must be considered. In this case, the delay was not vexatious, capricious, or oppressive.
  2. Collegiate Nature of the CA: Decisions in the CA are made collectively, requiring consultation and review by other justices. The delay was a necessary consequence of this process.
  3. No Violation of Judicial Conduct: The Court found that Justice Reyes acted promptly and diligently in studying the case, preparing a draft decision, and circulating it for review. The delay did not violate Rule 1.02 of Canon 1 of the Code of Judicial Conduct, which requires judges to administer justice impartially and without delay.
  4. Balancing of Interests: The Court noted that while complainants sought urgent relief, the responsible officers of the PNPA also had a duty to maintain the integrity of the institution. Balancing these interests required careful consideration, which justified the delay.


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