Title
Bautista vs. Causapin, Jr.
Case
A.M. No. RTJ-07-2044
Decision Date
Jun 22, 2011
Heirs filed a partition case; judge dismissed it improperly, granted defective extensions, and engaged in misconduct, leading to Supreme Court sanctions for gross ignorance and misconduct.
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Case Digest (A.M. No. RTJ-07-2044)

Facts:

  1. Filing of the Complaint for Partition
    On December 15, 2005, the heirs of Baudelio T. Bautista and Aurora T. Bautista, represented by Delia R. Bautista and Reynaldo B. Mesina, respectively, along with other plaintiffs, filed a Complaint for Partition against Jose Bautista and Domingo T. Bautista (defendants) before the Regional Trial Court (RTC) of Guimba, Nueva Ecija, docketed as Civil Case No. 1387-G. The case was assigned to Judge Blas O. Causapin, Jr.

  2. Motions for Extension of Time to File Answer
    The defendants filed three motions for extension of time to file their answer:

    • On January 24, 2006, they filed a motion for a 15-day extension, which Judge Causapin granted on January 25, 2006.
    • On February 6, 2006, they filed a second motion for a 15-day extension, which Judge Causapin granted on the same day, labeling it as "inextendible."
    • On February 20, 2006, they filed a final motion for a 10-day extension, which Judge Causapin also granted on the same day.
  3. Defects in the Motions for Extension
    Atty. Facundo T. Bautista, the plaintiffs' counsel, pointed out that all three motions for extension lacked a notice of hearing, rendering them mere "scraps of paper" under the Rules of Court.

  4. Filing of the Answer and Motion to Dismiss
    On March 20, 2006, the defendants filed their joint Answer with Counterclaim and Motion to Dismiss. The plaintiffs countered by filing a motion to declare the defendants in default on March 27, 2006.

  5. Hearings on the Motion to Declare Defendants in Default
    The motion to declare the defendants in default was set for hearing multiple times, with delays caused by the defendants' requests for additional time and the plaintiffs' failure to appear on some occasions.

  6. Dismissal of the Complaint
    On September 18, 2006, Judge Causapin dismissed the complaint without prejudice, citing two main reasons:

    • The verification and certification of non-forum shopping were not signed by two of the plaintiffs, Reynaldo Mesina and Nancy Polangco, in violation of Rule 7, Section 5 of the Rules of Court.
    • The complaint did not properly name all compulsory parties, violating Rule 3, Sections 2, 3, and 7 of the Rules of Court.
  7. Administrative Complaint Against Judge Causapin
    Atty. Bautista filed an administrative complaint against Judge Causapin for gross ignorance of the law and gross misconduct, alleging that:

    • Judge Causapin improperly granted the defendants' motions for extension of time without notice of hearing.
    • Judge Causapin dismissed the complaint without a hearing, violating procedural rules.
    • Judge Causapin exhibited bias by having drinking sprees with one of the defendants and requesting Atty. Bautista to withdraw the motion to declare the defendants in default.

Issue:

  1. Whether Judge Causapin committed gross ignorance of the law by:

    • Granting the defendants' motions for extension of time to file their answer without notice of hearing.
    • Dismissing the complaint without a hearing based on the defective verification and certification of non-forum shopping.
  2. Whether Judge Causapin committed gross misconduct by:

    • Engaging in improper conduct, such as drinking sprees with one of the defendants.
    • Requesting Atty. Bautista to withdraw the motion to declare the defendants in default.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

Judge Causapin was found guilty of gross ignorance of the law and gross misconduct. The Court imposed a fine of P20,000.00, to be deducted from his retirement benefits or accrued leave credits.


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