Case Digest (A.M. No. MTJ-91-598) Core Legal Reasoning Model
Facts:
In the case of A.M. No. MTJ-91-598, dated February 9, 1993, Atty. Cornelio C. Cruz filed a verified administrative complaint against Judge Romulo C. Basa, who was presiding over the Municipal Trial Court (MTC) in Norzagaray, Bulacan. The complaint was lodged on September 19, 1991, alleging serious misconduct on the part of the judge. The complainant was the private prosecutor in twenty estafa cases, specifically Crim. Cases Nos. 4194 to 4204-b, 4205 to 4208, 4216, 4219, and 4226, against an individual named Rodolfo Cruz. The basis for the complaint arose from the accused's alleged misappropriation of various amounts ranging from over P200.00 to not more than P6,000.00.
Cruz claimed that Judge Basa had delayed ruling on a motion to dismiss the cases filed by Rodolfo Cruz, which was based on the argument that the prosecution should follow the Rule on Summary Procedure. The complainant opposed this motion, citing Article 315 of the Revised Penal Code, which indicated that the
Case Digest (A.M. No. MTJ-91-598) Expanded Legal Reasoning Model
Facts:
Atty. Cornelio C. Cruz, acting as private prosecutor in twenty criminal cases of estafa against Rodolfo Cruz in the Municipal Trial Court of Norzagaray, Bulacan, filed an administrative complaint against Judge Romulo C. Basa. The complaint charged the judge with serious misconduct for delaying the disposition of a motion to dismiss the criminal cases and for causing a false Monthly Report dated April 30, 1991, to be submitted to the Supreme Court’s Statistics Division wherein these cases were erroneously recorded as “disposed.” Despite having prepared a final draft resolution disposing of the pending issue, the judge did not sign or release it due to the numerous motions filed by the complainant and later, following advice from the Executive Judge of Malolos, Bulacan, he opted to inhibit himself from trying the cases. Notably, his delay extended from the beginning of the oral argument on February 18, 1991, until at least June 3, 1991, when the complainant filed a motion to inhibit him from further trying the cases. Subsequent evidence, including orders dated June 19 and August 5, 1991, confirmed that the cases were still pending even though the Monthly Report inaccurately reflected otherwise. The judge’s commentary admitted a delay in resolution, attributing it to the heavy caseload and the subsequent filing of motions for inhibition, but failed to justify the submission of a false report indicating resolution.Issues:
- Whether Judge Basa’s failure to dispose of the motion to dismiss within a reasonable time constituted serious misconduct and inaction amounting to partiality.
- Whether the submission or causing the submission of a false Monthly Report listing the cases as “disposed” despite them still being pending constituted a violation of judicial ethics and the rules governing prompt disposition of cases.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)