Facts:

The case at bar involves a complaint filed on February 17, 1997, against Judge Felix A. Caraos, who presides over the Municipal Trial Court of Candelaria, Quezon. The complainants, consisting of Manuel Buny, Anatalia Atienza, Alfredo Laygo, Isidro de Gala, Reynaldo Marquez, Nestor Baera, and Olimpio Bukid, are members of the Sangguniang Bayan of Candelaria. In 1996, the Sangguniang Bayan resolved to demolish the old public market building in the poblacion to construct a new one. They designated a temporary market site approximately one kilometer away for the vendors. A resolution was also passed to prohibit vendors from operating in the PNR compound, which was not the designated site. Despite this, over 300 market vendors began operating in the PNR compound without a Mayor's permit, leading to a decline in municipal income due to unpaid rentals and fees. Efforts by the Mayor and the Provincial Governor to relocate the vendors were unsuccessful, prompting police action to ...

Facts:

1. Background of the Case:

   • Complainants are members of the Sangguniang Bayan of Candelaria, Quezon.
   • In 1996, the Sangguniang Bayan decided to demolish the old public market building to construct a new one.
   • A temporary market site, one kilometer away from the poblacion, was designated for market vendors.
   • A resolution was passed prohibiting vendors from operating in the PNR compound, which was not the designated temporary site.

2. Vendors' Actions:

   • Over 300 market vendors began operating in the PNR compound without a Mayor's permit.
   • They stopped paying daily rentals and fees to the Municipal Treasurer, causing a decline in municipal income.
   • Despite efforts by the Mayor and Provincial Governor, the vendors refused to relocate.

3. Legal Actions Taken:

   • The police drove the vendors away from the PNR compound and filed criminal cases against them before the Municipal Trial Court of Candelaria, presided by respondent Judge Felix A. Caraos.
   • The vendors persisted in returning to the compound, destroying fences and continuing their business.

4. Delays in Judicial Proceedings:

   • The criminal cases, filed in June 1996, were set for arraignment on December 10, 1996, and trial on January 28, 1997.
   • Respondent Judge failed to appear on the trial date without explanation.
   • As of the filing of the complaint on February 17, 1997, the cases remained pending.

5. Allegations of Partiality:

   • Complainants alleged that respondent Judge prejudged the case by stating that the Mayor had made a mistake in relocating the vendors.

6. Respondent's Defense:

   • Respondent Judge claimed the delay was due to political conflict, civic organizations' involvement, and postponements by both parties.
   • He denied partiality, stating his comments were personal observations made in response to a query.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Inefficiency in Case Disposition:

   • The criminal cases, being violations of a municipal ordinance, fell under the Revised Rule on Summary Procedure, which mandates expeditious resolution.
   • Respondent Judge's failure to resolve the cases within one year constituted inefficiency and violated the Code of Judicial Conduct, which requires judges to dispose of cases promptly.

2. Appearance of Partiality:

   • Judges must not only be impartial but must also appear impartial to maintain public confidence in the judiciary.
   • Respondent Judge's comments on the relocation of vendors, though not malicious, created an impression of bias, which is unacceptable for a judicial officer.

3. Judicial Accountability:

   • Judges are held to high standards of conduct and are expected to administer justice without delay.
   • Delays in court proceedings undermine public trust in the judiciary and tarnish its image.