Title
Bonilla vs. Gustilo
Case
A.M. No. RTJ-00-1569
Decision Date
Nov 22, 2000
Judge Tito Gustilo admonished for undue delay in case disposition; reassignment of Judge Bonilla deemed lawful, abuse of authority charge dismissed.
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Case Digest (A.M. No. RTJ-00-1569)

Facts:

Background of the Case

  • Judge Melchor E. Bonilla, Presiding Judge of the 16th MCTC, Jordan-Buenavista-Nueva Valencia, Guimaras, filed a sworn letter-complaint on June 15, 1998, against Judge Tito A. Gustilo, Executive Judge of Branch 23, RTC, Iloilo City.
  • The complaint alleged Undue Delay in the disposition of AM No. MTJ-94-923 (Elena E. Jabaco v. Judge Melchor Bonilla) and Grave Abuse of Authority.

Undue Delay Allegations

  • The Supreme Court issued a resolution on March 23, 1998, directing Judge Gustilo to investigate, report, and recommend within 60 days from receipt of the records.
  • Despite the lapse of four years, Judge Gustilo failed to submit his report and recommendation.
  • The investigation of the case was allegedly terminated on August 16, 1996.

Grave Abuse of Authority Allegations

  • Judge Gustilo ordered Judge Bonilla’s relief as Presiding Judge of the 16th MCTC and designated him as Acting Presiding Judge of MTC, Barotac, Iloilo, without authority from the Supreme Court or the Court Administrator.
  • Judge Bonilla filed a motion for reinstatement to his original station on September 8, 1995, but it was unacted upon despite an indorsement from Deputy Court Administrator Bernardo Abesamis.
  • After deciding the remaining cases in Barotac Nuevo, Judge Bonilla requested to return to his original station but was denied.
  • Judge Bonilla suffered hardships, including a vehicular accident on September 7, 1994, while traveling to his assigned court.

Respondent’s Defense

  • Judge Gustilo explained that the delay was due to the voluminous records and numerous postponements, including the suspension of hearings when Judge Bonilla met an accident.
  • He justified the reassignment of Judge Bonilla as necessary due to the deep-seated conflict between Judge Bonilla and his Clerk of Court, Elena Jabao, which he deemed prejudicial to the service.

Timeline of Events

  • The last hearing of the case was conducted on August 16, 1996.
  • Judge Gustilo submitted his Report and Recommendation on June 18, 1998, received by the Court on August 11, 1998.
  • The administrative complaint was filed on June 15, 1998, and received by the Court on June 22, 1998.

Issue:

  1. Whether Judge Tito A. Gustilo is guilty of Undue Delay in the disposition of AM No. MTJ-94-923.
  2. Whether Judge Tito A. Gustilo committed Grave Abuse of Authority in reassigning Judge Melchor E. Bonilla without proper authority.

Ruling:

  • The Supreme Court found Judge Tito A. Gustilo guilty of Undue Delay in the disposition of AM No. MTJ-94-923.
  • The charge of Grave Abuse of Authority was dismissed for lack of merit.
  • Judge Gustilo was admonished for the undue delay, with a warning that a repetition of the same would be dealt with more severely.

Ratio:

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