Title
Bascug vs. Arinday, Jr.
Case
A.M. No. RTJ-00-1591
Decision Date
Apr 11, 2002
Judge found guilty of gross inefficiency and grave misconduct for delayed rulings, improper judgment on pleadings, and procedural irregularities, fined P5,000.
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Case Digest (A.M. No. RTJ-00-1591)

Facts:

Civil Cases No. 1797-69 and No. 1798-69

  • Complainant Laurentino D. Bascug filed a complaint against Judge Graciano H. Arinday, Jr., for grave misconduct, knowingly rendering an unjust judgment, malicious delay in the administration of justice, and violation of the code of judicial conduct.
  • The civil cases, originally filed in the Municipal Circuit Trial Court (MCTC) of Victorias-Manapla, Negros Occidental, were dismissed on 15 May 1995 due to the absence of a certificate of barangay conciliation.
  • The plaintiffs appealed to the Regional Trial Court (RTC) of Silay City, where the cases were assigned to respondent judge. On 20 October 1995, respondent judge reversed the MCTC decision and ordered further proceedings.
  • A motion for reconsideration filed by the defendants was denied because it lacked the signature of their counsel. A second motion for reconsideration was filed on 16 January 1996, which respondent judge gave due course to on 23 January 1996.
  • The second motion for reconsideration was ultimately denied on 12 November 1996, but the records were only remanded to the MCTC on 13 June 1997. Complainant alleged that the delay was due to the influence of the mayor of Victorias over respondent judge.

Civil Case No. 1718-69

  • Complainant charged respondent judge with gross misconduct for directing a judgment on the pleadings in favor of the plaintiffs, despite the defendant corporation (of which complainant was President) not agreeing to it.
  • Respondent judge issued an order on 20 December 1994 requiring the parties to submit memoranda for judgment on the pleadings. The defendant corporation did not submit any memorandum.
  • On 4 April 1995, respondent judge rendered a judgment on the pleadings in favor of the plaintiffs. A motion for reconsideration was denied on 11 December 1995.
  • The Court of Appeals later set aside the judgment on 14 August 1998 and remanded the case for further proceedings.

Criminal Case No. 4000-69

  • Complainant alleged irregularities in the service of the warrant of arrest and accused respondent judge of failing to commence prosecution against the accused.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Gross Inefficiency: A motion for reconsideration must be resolved within 30 days from submission. Respondent judge failed to act promptly, delaying the resolution of the second motion for reconsideration and the remanding of records, which constituted gross inefficiency.
  2. Grave Misconduct: Judgment on the pleadings is only proper when the answer fails to tender an issue or admits the material allegations of the adverse party. In Civil Case No. 1718-69, the defendant corporation did not agree to submit the case for judgment on the pleadings, and no memorandum was filed. Respondent judge’s actions fell below the standard of conduct expected of a judge.
  3. Judicial Integrity: Delays in the disposition of cases erode public trust in the judiciary. Judges must act with circumspection and efficiency to maintain the integrity of the judicial system.


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