G.R. No. 83558 - National Power Corp. vs. Vera

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.

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).

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.

Based on these findings, Judge Arche recommended that the respondent be "warned to be more careful" in performing his judicial duties according to the norms under the New Society.

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

He acknowledged that although the respondent erred in dismissing the petition (specifically regarding the Bo. Bagua, Guiuan election result), this mistake was characterized as an error of judgment lacking bad faith or malice.
The justification relied partly on the fact that most petitioners (except one) had denied the material allegations in the petition and that the respondent was acting under the requirement of verification as stipulated in Rule 7, Sec. 5 of the New Rules of Court.

The records indicated that the motion, filed on April 3, 1972, pending resolution from February 18, 1972, was not acted upon until October 16, 1972.
Justice Barcelona criticized the respondent for his prolonged inaction, highlighting that his later inhibition (to avoid implicating his brother) came off as an evasion to escape liability.
The report pointed out inconsistencies, particularly how the respondent had previously ruled against the annulment petition despite clear evidence in the petition implicating his brother.

As a disciplinary measure, Justice Barcelona recommended the suspension of Judge Sison for one (1) month without pay as a deterrent for future negligence.

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.

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.