Case Digest (SB-99-9-J)
Facts:
Canson v. Garchitorena, SB-99-9-J, July 28, 1999, First Division, Ynares‑Santiago, J., writing for the Court. Complainant Jewel F. Canson (a respondent in the underlying criminal cases) filed an administrative complaint with the Office of the Court Administrator (OCA) on February 24, 1997 against several Justices of the Sandiganbayan Second Division, later amending his complaint on April 16, 1997 to name only Presiding Justice Francis E. Garchitorena and Associate Justice Sabino R. de Leon, Jr. as respondents for alleged delay in resolving motions for reconsideration and for gross misconduct in delaying the transfer of Criminal Case Nos. 23047–23057 (People v. Chief Insp. Michael Ray Aquino, et al.).The OCA record shows that the Ombudsman filed eleven informations for murder against PNP personnel on November 21, 1995, later amended March 1, 1996 to downgrade the liability of Chief Superintendent Panfilo M. Lacson. On May 8, 1996 the Sandiganbayan, by a 3–2 vote, issued a resolution admitting the amended information and ordering transfer of the cases to the Regional Trial Court (RTC), Quezon City. The public and private prosecutors filed motions for reconsideration on May 17 and 22, 1996; those motions remained unresolved for almost ten months despite several motions for early resolution.
While the motions remained pending, legislation to amend Sandiganbayan jurisdiction (House Bill No. 5323; Senate counterpart and hearings) culminated in the enactment of R.A. No. 8249 (signed February 5, 1997), whose transitory provisions could have affected the proper forum for the cases. The Sandiganbayan later issued a Resolution dated September 4, 1996 (promulgated March 5, 1997) resolving the motions for reconsideration; that resolution bore various concurrences and dissents, showing divergent views among the Second Division members.
The OCA transmitted the administrative matter to the Court. The Supreme Court required comments and pleadings from respondents, entertained a motion to dismiss as to Justice de Leon (which complainant joined), and on October 12, 1998 dismissed the complaint as to Justice de Leon and excused him from further participation. The Court then considered whether respondent Justice Garchitorena was administratively liable for violating Section 7, P.D. No. 1606, Rule VIII of the Revised Rules of the Sandiganbayan...(Pro-only)
Issues:
- Was respondent Justice Francis E. Garchitorena administratively liable for unreasonably delaying the resolution of the motions for reconsideration in Criminal Case Nos. 23047–23057 in violation of Section 7, P.D. No. 1606; Rule VIII of the Revised Rules of the Sandiganbayan; and the Canons of Judicial Conduct?
- If administratively liable for delay, did that delay constitute gross misconduct warranting ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
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