G.R. No. 170606 - LCK Industries Inc. vs. Planters Development Bank

Complainants Freddie J. Farres and Orwen L. Trazo filed a Joint Affidavit Complaint against Judge Edgardo B. Diaz De Rivera, Jr. of Branch 10, RTC La Trinidad, Benguet.
The complaint involved alleged violations of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) as well as Canon 3 and Canon 5 of the Code of Judicial Conduct.
The allegations centered on the judge’s handling of Criminal Case No. 11-CR-8444, a case involving violations under Presidential Decree No. 705 (The Revised Forestry Code of the Philippines).

The criminal case was raffled to the respondent judge in May 2011.
Despite the filing of the case, there were only four hearings conducted over a span of more than three years, with the prosecution yet to complete its presentation of witnesses at the time of the complaint.
There were multiple postponements and cancellations of hearings due to various factors including absence of counsel, inclement weather, and administrative issues.
Detailed chronological incidents within the case:

May 23, 2011: Filing of the Information with the accused already detained.
June 14-21, 2011: Arraignment and postponement due to absence of the retained counsel; defendants pleaded not guilty.
Subsequent pretrial hearings were scheduled with frequent cancellations (e.g., August and September 2011) due to absence of defense counsel, inclement weather, or deferrals for reinvestigation.
From June 2012 to September 2012, several trial hearings took place involving the presentation and cross-examination of prosecution witnesses, with some hearings marred by the absence of counsel and fines imposed for non-attendance.
In October 2012, the respondent judge suffered a severe stroke which paralyzed the left side of his body, leading to hospital confinement and a series of medically necessitated leaves of absence.
Despite his health condition, the judge reportedly resumed hearings in 2013 without formally seeking an extension or notifying the court of his incapacity to decide the case promptly.

In the criminal case, both accused were allowed by the respondent judge to post a cash bail set at P10,000 each, which represented a significant reduction from the recommended P40,000 by the Benguet Provincial Prosecutors Office.
Complainants pointed out that in comparative cases involving PD No. 705, accused parties were not granted bail reductions exceeding 50%, highlighting an inconsistency in practice.
The respondent judge justified the bail reduction on the grounds of the accused’s financial incapacity, citing their youth, unemployment, and dependent status.
During the hearing on the bail reduction motion, prosecutors and other parties submitted no objection, ultimately leaving the decision within the sound discretion of the court.

The Office of the Court Administrator (OCA) recommended re-docketing the administrative complaint as a regular administrative matter against the respondent judge.
The OCA further recommended that the judge be found liable for violation of Supreme Court rules, directives, and circulars governing the speedy disposition of cases.
The OCA initially recommended a fine of P5,000 to be deducted from the judge’s disability retirement benefits.
The respondent judge had previously filed an application for disability retirement, effective April 30, 2015.
The evidentiary record in the administrative proceedings included both the detailed chronology of the case and the judge’s explanations regarding his health-related absences and management of the case schedule.

Whether the respondent judge’s actions constituted a violation of the Supreme Court rules on prompt case management and the directives of the Administrative Circulars requiring strict observance of session hours.

Determination of whether the prolonged delay in the disposition of Criminal Case No. 11-CR-8444 was attributable to the judge’s conduct rather than solely to external factors such as counsel absences or inclement weather.

Whether the reduction of the bail from the recommended amount of P40,000 to P10,000 was improper and indicative of bias or undue leniency.

Assessment of the propriety of allowing such a reduction given the financial status of the accused and the absence of objection from other court personnel and prosecutors.

Whether the judge’s justification leveraging his health condition (i.e., a stroke and subsequent leaves of absence) sufficiently excused his failure to manage and dispose of the case within the required reglementary period.

Whether the judge should have formally notified the court or requested an extension to mitigate the impact of his health issues on the administration of justice.