Facts:

This case involves a complaint filed by Maximino Balayo (the complainant) against Judge Mamerto M. Buban, Jr., the Regional Trial Court Judge of Branch 18 in Tabaco, Albay (the respondent). The complaint was lodged on September 9, 1999, concerning various charges including failure to decide a case within the required timeframe, falsification of public documents, violation of the Anti-Graft and Corrupt Practices Act, and gross ignorance of the law. The complainant, who was the defendant in Civil Case No. T-1577 pertaining to accion publiciana, alleged that the case was submitted for decision to the respondent in November 1995 but was only resolved on March 24, 1997.

Balayo contended that the decision was fundamentally flawed as Judge Buban relied on hearsay and unsupported assertions in his ruling. Specifically, he criticized Judge Buban for fabricating the testimony of a witness, Nelson Carretas, who allegedly presented crucial documentary evidence that was never actually submi

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Facts:

Background of the Complaint

• Complainant Maximino Balayo filed a complaint against Judge Mamerto M. Buban of the Regional Trial Court, Branch 18, Tabaco, Albay.
• The allegations include:
• Failure to decide a case within the reglementary period.
• Falsification of public documents.
• Violation of the Anti-Graft and Corrupt Practices Act.
• Gross ignorance of the law.

Specific Issues in Civil Case No. T-1577

• The case involves an accion publiciana where Balayo is the defendant.
• It is alleged that the case was submitted for decision in November 1995 but was only decided on March 24, 1997, exceeding the reglementary period.
• The delay was attributed by Judge Buban to his designation as acting presiding judge of another vacant sala.

Alleged Falsification and Erroneous Evidentiary References

• The complaint alleges that Judge Buban erroneously relied on the testimony of a witness, Nelson Carritas, who was never a witness in Civil Case No. T-1577:
• Nelson Carritas actually testified in a different case (Cadastral Case No. T-163) involving a Petition for Reconstitution of Title.
• He presented a salvaged list showing certificates of title for Lot 7493 and Lot 206, which were erroneously admitted as evidence in Civil Case No. T-1577.
• Judge Buban was further accused of basing his decision on hearsay and self-serving evidence:
• Relying on a testimony attributed to Arleen Azada regarding an alleged admission by the complainant before the Barangay Captain of Quinale, Tabaco, Albay, despite no such proceedings having been held.
• Introducing references to certificates of title from the 1930s, even though the lots in question were purportedly issued titles through land registration proceedings in the 1970s, thereby creating a chronological inconsistency.

Administrative Recommendations and Pending Judicial Proceedings

• The Office of the Court Administrator (OCA) recommended:
• Imposing a fine of ₱5,000.00 on Judge Buban for the failure to decide Civil Case No. T-1577 within the required period.
• Dismissing the other charges on the grounds that they are already involved in the pending appeal to the Court of Appeals.
• The complaint was noted to be premature since the complainant had perfected his appeal on the disputed decision.

Issue:

Timeliness of the Judicial Decision

• Was Judge Buban justified in taking an extended period (from November 1995 to March 1997) to decide Civil Case No. T-1577?
• Does the designation as acting presiding judge of another sala sufficiently excuse the delay?

Evidentiary Misstatements and Testimonial References

• Did Judge Buban commit an act of falsification or misrepresentation by referring to Nelson Carritas as a witness in Civil Case No. T-1577 when he only testified in Cadastral Case No. T-163?
• Is the reliance on alleged hearsay testimony from Arleen Azada about an admission by the complainant indicative of judicial partiality or negligence?

Overlapping Legal Remedies and Prematurity

• Should the administrative and criminal charges be entertained while an appeal on the decision in Civil Case No. T-1577 is pending before the Court of Appeals?
• Is it appropriate to initiate separate disciplinary proceedings for issues that are concurrently being contested in the appellate court?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)