G.R. No. L-24115 - Shaffer vs. Palma

German Wenceslao Cruz, Jr. (Complainant) initiated an administrative complaint against Judge Daniel C. Joven (Respondent) of the Second Municipal Circuit Trial Court, Sipocot-Lupi, Sipocot, Camarines Sur.
The complaint charged the judge with gross negligence, abuse of authority, dereliction of duty, and failure to render a decision within thirty days as mandated by the rules on summary procedure.
Complainant acted as the representative of the plaintiff estate in Civil Case No. 548 (“Estate of German Cruz vs. Gregorio Batalla”), which involved an unlawful detainer action.

The complaint was filed on February 22, 1996, and a summons along with a copy of the complaint was served on the respondent on February 28, 1996.
The defendant in the civil case did not file an answer within the reglementary period. Instead, counsel for the defendant submitted a motion for an extension of time to answer and concurrently moved for the inhibition of Respondent Judge.
The motion for extension was denied on the ground that it constituted a prohibited pleading under the Revised Rules on Summary Procedure, but the motion for inhibition was initially granted to ensure the court’s impartiality and cold neutrality.

The inhibition order was later denied by then Executive Judge Salvador G. Cajot of the Regional Trial Court of Libmanan, which directed Judge Joven to proceed with the case.
Complainant filed several motions (e.g., for judgment on the pleadings, to present evidence, and for judgment), yet the case remained unresolved.
On March 26, 1997, Judge Joven declared in an order that verdict would be rendered within thirty days due to the absence of an answer. However, no decision ensued.

After the arrival of a new Executive Judge (Hon. Thelma C. Villareal) in April 1997, Respondent Judge again inhibited himself from presiding over the case, citing that a pending administrative charge might affect his impartiality.
In his second response, Judge Joven admitted to inadvertently overlooking the motion to present evidence filed by the complainant, but further justified his self-inhibition by alleging that external pressures and personal gratitude owed to the complainant’s father could breach his neutrality.

The Office of the Court Administrator (OCA) reviewed the matter, found merit in the complaint, and recommended that it be re-docketed as an administrative case.
On March 29, 2000, the Court approved the OCA’s recommendation and directed the parties to state whether they would prefer the case to be resolved based on the existing pleadings and records.
The complainant affirmed this mode of resolution in his manifestation on May 6, 2000; however, Judge Joven failed to comply with the Court’s resolution.

Whether Judge Joven’s conduct—characterized by repeated self-inhibition and failure to decide the case—constitutes gross negligence and dereliction of duty in light of his obligations under the rules on summary procedure.
Whether such conduct, given the pending administrative complaint, justifies a finding of abuse of authority against a trial court judge.

Whether the filing of an administrative complaint or charge before the Ombudsman can serve as a valid ground for a judge to excuse himself from presiding over a case.
The impact of such self-inhibition on the prompt and efficient dispensation of justice in cases pending before the court.

Whether the delay in rendering a decision in Civil Case No. 548 adversely affects the litigants’ right to a speedy resolution of disputes.
How the judge’s actions align with or diverge from the expectations and standards laid down for municipal trial court judges in handling cases expeditiously.