Case Digest (A.M. No. RTJ-07-2044)
Facts:
The case involves an administrative complaint filed by Atty. Facundo T. Bautista against Judge Blas O. Causapin, Jr., the Presiding Judge of the Regional Trial Court (RTC), Branch 32 in Guimba, Nueva Ecija. The complaint was lodged on June 22, 2011, alleging gross ignorance of the law and gross misconduct. The events leading to the complaint began on December 15, 2005, when the heirs of Baudelio T. Bautista, represented by Delia R. Bautista, and the heirs of Aurora T. Bautista, represented by Reynaldo B. Mesina, along with other plaintiffs, filed a Complaint for Partition against Jose Bautista and Domingo T. Bautista, which was docketed as Civil Case No. 1387-G. The case was assigned to Judge Causapin's branch. The defendants were given until January 26, 2006, to file their answer but requested extensions multiple times, which Judge Causapin granted through several orders. Atty. Bautista objected to these extensions, arguing that they lacked proper notice of hearing. On M...
Case Digest (A.M. No. RTJ-07-2044)
Facts:
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.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.
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.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.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.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.
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:
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.
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.