Case Digest (A.M. No. RTJ-02-1718)
Facts:
The case involves Miguela Bontuyan as the complainant against Judge Gaudioso D. Villarin, who was serving as the Regional Trial Court (RTC) Judge of Branch 59 in Toledo City, Cebu, and previously as the Judge Designate of the Municipal Trial Court in Cities (MTCC) Branch 5 in Cebu City. The complaint was filed due to the alleged undue delay in rendering a decision in Criminal Case No. 34668-R, titled "People of the Philippines v. Antonio Belandres." The events leading to the complaint began when Bontuyan, on June 16, 1998, sent a letter to the Office of the Ombudsman for the Visayas, expressing her frustration over the continuous postponements of hearings in her case, which had been filed in September 1993. The Ombudsman forwarded her letter to the court on September 8, 1998.
On February 15, 1999, the Office of the Court Administrator (OCA) required Judge Villarin to submit a comment regarding the complaint. However, he failed to comply, prompting the issuance of...
Case Digest (A.M. No. RTJ-02-1718)
Facts:
Background of the Case: Miguela Bontuyan filed an administrative complaint against Judge Gaudioso D. Villarin for undue delay in rendering a decision in Criminal Case No. 34668-R, entitled People of the Philippines v. Antonio Belandres, a theft case filed in September 1993.
Complaint Details:
- On June 16, 1998, Bontuyan wrote to the Office of the Ombudsman for the Visayas, seeking assistance for the delayed resolution of her case. She alleged that Judge Villarin had repeatedly postponed hearings, causing significant delays.
- The complaint was forwarded to the Supreme Court, which received it on September 8, 1998.
Court's Action:
- On February 15, 1999, the Office of the Court Administrator (OCA) required Judge Villarin to submit a comment on the complaint.
- Judge Villarin failed to comply, prompting the OCA to issue a "1st Tracer" on May 29, 2001, directing him to submit his comment within five days.
- On June 18, 2001, Judge Villarin belatedly submitted his comment, stating that the case "has long been decided" and attributing the delay in submitting his comment to the distance between Toledo City and Cebu City.
OCA Findings:
- The OCA found that Judge Villarin failed to decide the case within the 30-day period required by the Rule on Summary Procedure, which applies to certain criminal cases.
- The OCA noted that Judge Villarin did not explain the cause of the delay or refute the allegations of undue postponements.
- The OCA recommended a fine of P2,000 and a warning against future similar acts.
Issue:
- Whether Judge Gaudioso D. Villarin is administratively liable for undue delay in rendering a decision in Criminal Case No. 34668-R.
- Whether the delay constitutes a violation of the Code of Judicial Conduct and the constitutional mandate to decide cases within the prescribed period.
Ruling:
The Supreme Court found Judge Gaudioso D. Villarin administratively liable for undue delay in rendering a decision and for violating Canon 3, Rule 3.05 of the Code of Judicial Conduct. The Court imposed a fine of P12,000 and warned him that future similar acts would be dealt with more severely.
Ratio:
Constitutional and Legal Mandate:
- The Constitution requires judges to decide cases within three months from the date of submission. Canon 3, Rule 3.05 of the Code of Judicial Conduct also mandates judges to dispose of court business promptly and decide cases within the required periods.
- Failure to decide a case within the prescribed period constitutes gross inefficiency and is a ground for administrative sanctions.
Failure to Justify Delay:
- Judge Villarin did not deny the charge of delay or provide any justification for it. He merely stated that the case "has long been decided" without addressing the reasons for the delay.
- The Court emphasized that judges must file applications for extensions if they cannot decide cases within the reglementary period, especially in complex cases. No such application was filed in this case.
Impact on Judicial Integrity:
- Undue delay in the disposition of cases erodes public confidence in the judiciary and brings it into disrepute. The Court stressed that justice delayed is justice denied.
- The Court reiterated that judges are expected to observe diligence and dedication in their duties to maintain the integrity of the judicial system.
Penalty Imposed:
- Undue delay in rendering a decision is classified as a less serious charge under Section 9, Rule 140 of the Rules of Court. The penalty for such a charge ranges from suspension without salary for one to three months or a fine of more than P10,000 but not exceeding P20,000.
- The Court imposed a fine of P12,000, consistent with the Rules, and issued a warning against future violations.