Title
Beduya vs. Alpuerto
Case
A.M. No. 1762-CTJ
Decision Date
Mar 31, 1980
Judge reprimanded for 2.5-year delay in decision; other charges dismissed due to unsubstantiated claims and complainant's disinterest.
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Case Digest (A.M. No. 1762-CTJ)

Facts:

  1. Case Background:

    • Manuel Beduya filed a verified complaint on November 3, 1977, against Municipal Judge Panfilo Alpuerto of Carmen, Cebu, in his capacity as Acting City Judge of Danao City.
    • The complaint alleged inefficiency and incompetence in the disposition of Criminal Case No. 2323, entitled "People vs. Francisco Tabla, Sr., et al." for grave coercion.
  2. Specific Allegations:

    • Delay in Decision: The case was submitted for decision on February 11, 1975, but the judgment was promulgated only on September 26, 1977, violating the constitutional requirement for timely decisions.
    • Failure to Address Conspiracy: The respondent judge failed to make any finding on conspiracy despite two accused being charged and sufficient evidence showing their concurrence.
    • Partiality in Decision: The respondent allegedly failed to address the third element of grave coercion, indicating partiality.
    • Ignoring Jurisprudence: The respondent acquitted the accused on the pretext of lack of force or intimidation, ignoring the directive to convict for a lesser offense.
  3. Respondent’s Defense:

    • Delay: The respondent admitted the delay but attributed it to ill-health caused by performing duties in two offices (Carmen, Cebu, and Danao City).
    • Conspiracy: He claimed he could not make a finding on conspiracy because the crime itself was not proven.
    • Third Element of Grave Coercion: He asserted that the matter was thoroughly discussed in his decision.
    • Acquittal: He argued that the accused could not be convicted of grave coercion due to insufficient evidence.
  4. Procedural Developments:

    • The case was referred to the Executive Judge of the Court of First Instance of Danao City for investigation.
    • During the hearing on February 27, 1979, the complainant manifested disinterest in prosecuting the case and requested its dismissal.
    • The Investigating Judge recommended dismissal due to the complainant’s lack of interest and failure to substantiate the charges.

Issue:

  1. Whether the respondent judge is administratively liable for the delay in rendering the decision in Criminal Case No. 2323.
  2. Whether the respondent judge’s failure to address conspiracy and the third element of grave coercion constitutes inefficiency or partiality.
  3. Whether the respondent judge’s acquittal of the accused, despite alleged sufficient evidence, demonstrates incompetence or disregard for jurisprudence.

Ruling:

  • The Supreme Court found the respondent judge administratively liable for the unreasonable delay in rendering the decision.
  • The delay of over two years and seven months violated the 90-day period mandated by law.
  • The Court reprimanded the respondent judge and warned that a repetition of the offense would be dealt with more severely.
  • The Court dismissed the other charges due to the complainant’s failure to substantiate them and his lack of interest in pursuing the case.

Ratio:

  1. Delay in Decision:

    • Judges are required to decide cases within 90 days from submission, as mandated by law. Failure to do so constitutes inefficiency and warrants administrative sanction.
    • The respondent’s admission of delay, coupled with the certification from the Clerk of Court, established his liability.
  2. Duty to Address All Elements of a Crime:

    • Judges must thoroughly address all elements of a crime in their decisions. However, the complainant’s failure to substantiate allegations of partiality or incompetence in this regard led to the dismissal of these charges.
  3. Acquittal Based on Insufficient Evidence:

    • Judges have the discretion to acquit if the prosecution fails to prove guilt beyond reasonable doubt. The respondent’s decision to acquit, based on insufficient evidence, was not deemed improper.
  4. Administrative Liability:

    • Even if the complainant withdraws the charges, the Court may still impose sanctions if the respondent’s liability is established, as in the case of the delay in decision-making.


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