Case Digest (A.M. No. RTJ-16-2455)
Facts:
Nemia Castro v. Judge Cesar A. Mangrobang, A.M. No. RTJ-16-2455 (Formerly OCA I.P.I. No.10-3443-RTJ), April 11, 2016, Supreme Court First Division, Leonardo‑De Castro, J., writing for the Court. Complainant Nemia Castro filed an administrative complaint against respondent Judge Cesar A. Mangrobang, then presiding judge of the Regional Trial Court, Branch 22, Imus, Cavite, alleging gross inefficiency, neglect of duty, gross ignorance of the law, and manifest bias and partiality arising from his handling of Civil Case No. 2187-00 (Castro v. Sps. Guevarra).The underlying civil suit, Civil Case No. 2187-00, was filed by Castro on October 5, 2000 against spouses Jamir and Rosalyn Guevarra for cancellation/discharge of checks and defamation/slander with damages. The case was initially raffled to RTC-Branch 90, presided by Judge Dolores Espanol, who rendered a Decision dated December 22, 2003 in favor of Castro, canceling or declaring without value several FEBTC checks and awarding damages; Judge Espanol also dismissed a related criminal case. The Decision mentioned denial of defendants’ motions for subpoenas and denial of their Motion to Defer Action pursuant to Section 7, Rule 65, 1997 Rules of Civil Procedure.
Spouses Guevarra moved for reconsideration (contending the Decision was promulgated after Judge Espanol’s retirement) and for re-raffle; the RTC Executive Judge re-raffled the case to RTC-Branch 22 (Judge Mangrobang). On December 15, 2004 Judge Mangrobang issued an Omnibus Order granting the spouses’ Motion for Reconsideration and setting the December 22, 2003 decision aside, and he held the proceedings in abeyance pending resolution of a then-pending certiorari petition in the Court of Appeals (CA-G.R. SP No. 80561).
The Court of Appeals later dismissed CA-G.R. SP No. 80561 as moot (July 20, 2006). Spouses Guevarra filed a Motion to Revive Proceedings / New Trial; on March 23, 2007 Judge Mangrobang granted it and set a new trial. Castro sought certiorari before the Court of Appeals (CA-G.R. SP No. 99763) challenging Judge Mangrobang’s March 23, 2007 order; the CA denied her petition on April 26, 2010 for failure to first file a motion for reconsideration and found no grave abuse of discretion, a denial later affirmed by this Court in G.R. No. 192737 (April 25, 2012), although this Court found the March 23, 2007 grant of new trial to be without legal basis but allowed the taking of evidence in the interest of justice.
Meanwhile, disputes arose in RTC-Branch 22 about suspension of proceedings while appellate petitions were pending, denial of Castro’s Motion for Inhibition (July 30, 2009), and alleged delays in resolving Castro’s Omnibus Motion (filed August 26, 2009) and Motion to Admit Postmaster’s Certification (filed September 18, 2009). Castro filed the administrative Complaint-Affidavit against Judge Mangrobang with the Office of the Court Administrator (OCA) on June 15, 2010, asserting (among other things) that the judge acted with bias and failed to act within the 90-day reglementary period required by the Constitution and rules.
The OCA investigated and recommended dismissal of charges of gross ignorance of the law and manifest bias (as judicial acts) but found merit in the charge of undue delay in rendering an order, r...(Pro-only)
Issues:
- Should respondent Judge Mangrobang have inhibited himself from hearing Civil Case No. 2187-00 on the ground of bias or partiality?
- Was Judge Mangrobang guilty of undue delay in resolving Castro’s pending motions, warranting administrative sanction, and if...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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