G.R. No. 156228 - Vidal vs. Escueta

This is an administrative complaint filed against Judge Jaime T. Hamoy for alleged Abuse of Authority, Dereliction of Duty, and Violation of Rule 3.05 of the Code of Judicial Conduct.
Complainant Jose E. Fernandez, acting as counsel for the plaintiffs in two civil cases filed in the Regional Trial Court (RTC) of Zamboanga City, Branch 15, raised concerns regarding the undue delay in the disposition of those cases.

Civil Case No. 3645: Hadji Adil Musahari, Plaintiff versus Shop-O-Rama, et al.
Civil Case No. 2744: Philippine International Development, Inc., Plaintiff versus Associate Citizens Bank, Defendant.

Respondent: Judge Jaime T. Hamoy, who, after a long period with unresolved cases at the RTC of Zamboanga City, was transferred to the RTC of Caloocan City, Branch 130.

Despite the lapse of more than ten years since the issuance and filing of the civil cases, Judge Hamoy failed to render judgments in both cases.
After his transfer, it was discovered that the judge had transferred the records of the unresolved cases to his new station without clearance from the Office of the Court Administrator (OCA).
Multiple directives from the Court Administrator and Deputy Court Administrators were issued:

On January 7, 1997, a letter from the complainant requested prompt action.
Senior Deputy Court Administrator Reynaldo L. Suarez referred the letter to the judge for comment.
Subsequent directives from Court Administrator Alfredo L. Benipayo and Deputy Court Administrator Jose P. Perez mandated that the judge file a comment on his inaction within specified periods.

The judge repeatedly failed to comply with these directives until a show-cause order was issued.

Forgetfulness in submitting his comment.
Misplacement of case records due to a mix-up by his utility aide.
The eventual discovery of the records only during a transfer to newly-acquired filing cabinets.
An excessive workload, especially given his responsibilities in the designated Family Court.

He later filed a Manifestation, claiming that he had rendered decisions on Civil Case No. 2744 on July 11, 2003, and on Civil Case No. 3645 on June 20, 2003.
Despite these submissions, the explanations provided were deemed insufficient to justify the extensive delay and noncompliance with administrative instructions.

Whether the respondent judge’s prolonged failure to render judgments in Civil Case Nos. 3645 and 2744 constitutes gross inefficiency and dereliction of duty.
Whether the repeated non-compliance with the directives of the Office of the Court Administrator and this Court amounts to a violation of Rule 3.05 of the Code of Judicial Conduct.
Whether the justification provided by the respondent—such as the alleged mix-up of records and an overwhelming caseload—is acceptable under the standards required for judicial efficiency and accountability.
Whether the court should impose a penalty more severe than a fine in view of the gravity of the misconduct and the adverse impact on the integrity of the judicial process.