Facts:

This case involves an administrative complaint filed by Francisco Awa-ao against Judge Ramon P. Sison, Jr., who was serving as the acting Municipal Judge of Guiuan, Eastern Samar at the time of the alleged misconduct. The complaint revolves around Judge Sison's handling of Barrio Election Case No. 127, which pertained to the annulment of election results for barrio officials. The events leading to the complaint began when Awa-ao and other aggrieved parties filed a petition for annulment of the election results, which Judge Sison subsequently dismissed on February 18, 1972. The dismissal was premised on the respondents’ lack of personal knowledge about the material facts alleged in the petition. Following this dismissal, Awa-ao filed a motion for reconsideration on April 3, 1972. However, the motion was not acted upon by Judge Sison for nearly nine months, creating further grievances among the complainants. The matter was escalated to the Executive Judge, Andres P. Arche, who

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Facts:

Background of the Case

• A complaint was filed by Francisco Awa-Ao against Judge Ramon P. Sison, Jr., who at the time was serving as the acting Municipal Judge of Guiuan, Eastern Samar.
• The administrative complaint centered on his performance in Barrio Election Case No. 127, which sought the annulment of the election of barrio officials.

Allegations Against the Respondent

• It was charged that Judge Sison dismissed the complaint against the annulment of the election improperly and in ignorance of the law.
• Additionally, there was a significant delay in resolving the motion for reconsideration of his dismissal order—a delay purportedly extending well beyond the ninety (90) day period provided by the Judiciary Act of 1948 (as amended).

Investigation Process

• The case underwent the usual preliminary processes before being referred for investigation.
• The Executive Judge of the Court of First Instance of Eastern Samar, Judge Andres P. Arche, was directed to investigate the matter.
• Judge Arche’s investigation revealed:

- Complainants, with the exception of Francisco Awa-Ao, admitted to lacking personal knowledge of the material facts complained of, thereby casting doubts on the substantive nature of the charges. - The dismissal of the complaint was based on these admissions, rendering the charge as somewhat “sham” in nature. - The delay in resolving the motion for reconsideration was addressed by the respondent’s explanation that upon learning of his brother’s (Atty. Cornelio Sison, then Mayor of Guiuan) involvement in the barrio election affair, he chose to inhibit himself from further action. - Judge Arche opined that since the motion subject of reconsideration pertained to the respondent’s own ruling, he was best positioned to resolve it, making his inhibition particularly questionable.

Judicial Consultant’s Report

• Justice Manuel P. Barcelona, serving as the Judicial Consultant, submitted a comprehensive report addressing two major issues:

- On the dismissal of the petition: - On the delay in disposing of the motion for reconsideration:

Contextual Circumstances

• A key element in the controversy was the designation of Judge Sison as the acting judge in a municipality where his younger brother was serving as mayor.
• This familial connection raised questions of conflict of interest that were not adequately disclosed prior to the appointment, thus exacerbating suspicions of impropriety.
• The matter, encompassing both technical judicial procedures and potential personal bias, underscored the critical importance of impartiality, especially in politically sensitive cases like barrio elections.

Issue:

• Whether the respondent, Judge Ramon P. Sison, Jr., committed acts amounting to administrative neglect in dismissing the petition for annulment of the election result in Bo. Bagua and in delaying the resolution of the motion for reconsideration.
• Whether the delay in acting on the motion for reconsideration—extending nearly nine (9) months—constituted a dereliction of duty that warranted disciplinary measures.
• Whether the designation of the respondent as acting judge in Guiuan, where his brother was the mayor, exacerbated issues of conflict of interest and undermined the integrity of the judicial process.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)