G.R. No. L-43451 - Capinpin vs. Workmen's Compensation Commission

Ernesto Hebron (Hebron) filed an administrative complaint dated September 30, 2011 with the Office of the Court Administrator (OCA) against Judge Matias M. Garcia II (Judge Garcia) charging gross ignorance of the law, incompetence, abuse of authority, and abuse of discretion.
Hebron was the complainant in Criminal Case No. CC-07-43, a case for falsification of public document which Hebron filed against Aladin Simundac (Simundac) relative to the latter’s application for free patent over a property in Carmona, Cavite.
After the Municipal Trial Court (MTC) of Carmona, Cavite denied Simundac’s motion to suspend proceedings, Simundac filed with the Regional Trial Court (RTC) of Bacoor, Cavite a petition for certiorari with prayer for issuance of temporary restraining order (TRO) and writ of preliminary injunction, docketed as BSC No. 2009-02, and raffled to RTC Branch 19 presided by Judge Garcia.

Hebron filed a motion for Judge Garcia’s inhibition, alleging perceived bias and partiality, citing that Judge Garcia had earlier dismissed Civil Case No. BCV-2005-94 filed by Hebron against Simundac.
A hearing on Simundac’s application for injunctive writ was conducted on April 16, 2009, when Judge Garcia issued an Order stating:

Atty. Frolin Remonquillo filed a Motion to Inhibit received by the Court only the day before.
Atty. Bingle B. Talatala moved that she be given ten (10) days to file a comment.
Atty. Remonquillo prayed for the same number of days to file a reply if necessary.
Both parties agreed to maintain the status quo until the Court resolved the incident.

On June 2, 2009, Judge Garcia set for June 8, 2009 another hearing on the application for TRO.
On June 8, 2009, Judge Garcia issued an Order stating that by agreement of the parties, they were given time to file their respective position papers.
On September 18, 2009, Judge Garcia finally issued an Order granting Simundac’s application for preliminary injunction, resulting in the suspension of proceedings in Criminal Case No. CC-07-43.
In the same September 18, 2009 Order, Judge Garcia denied Hebron’s motion for inhibition.

Hebron filed a Motion for Reconsideration of the Order dated September 18, 2009.
Hebron later alleged that, despite his filings:

On October 30, 2009, Hebron, through counsel, filed a Motion for Reconsideration of Judge Garcia’s September 18, 2009 Order.
On November 25, 2009, accused through counsel filed a comment on the motion for reconsideration, and the motion was submitted for resolution.
On April 20, 2010, Hebron filed a motion to resolve and set the motion for reconsideration for hearing on April 29, 2010.
On September 7, 2010, Hebron filed a second motion to resolve and set the motion for reconsideration for hearing on September 28, 2010.

Hebron stated that up to his administrative complaint, one (1) year, nine (9) months, and fourteen (14) days had lapsed without notice of resolution being sent to counsel.
Hebron cited that any motion not acted upon within the time prescribed by the rules was contrary to Aries vs. Beldia, 476 SCRA 298.

In his Comment, Judge Garcia gave a lengthy discussion of the bases for his past rulings.
On the failure to immediately resolve Hebron’s motion for reconsideration, Judge Garcia explained that:

The Motion for Reconsideration was inadvertently not acted upon for an unreasonable length of time.
The Court noticed the pending motion only during its inventory of cases in July 2011, with the inventory extended to September 2011 due to the program titled Case Delay and Docket Reduction Project (CDDRP), in which the RTC Branch was a pilot court.
For about five (5) months, the Court allegedly stopped proceedings to give way to the program.
The delay was not allegedly deliberately and maliciously motivated.
The Court was allegedly swamped with thousands of cases, and as of July 2011 it had about 3,788 pending cases, and from January to October 2011 about 879 cases were raffled.
Judge Garcia claimed the overload had been brought to the attention of the CDDRP and that solutions required creation of new salas.
Judge Garcia promised that the same incident would not happen again and stated that if it could not be avoided, he would file an extension of time to resolve.

Whether Hebron’s withdrawal necessarily required dismissal of the administrative case.

Whether the administrative charges concerning Judge Garcia’s adjudicative rulings warranted administrative liability

Whether the alleged distorted facts, alleged absence of agreement on June 8, 2009, and alleged erroneous issuance of preliminary injunction without a proper hearing constituted administrative wrongdoing cognizable in an administrative complaint.
Whether Judge Garcia’s alleged bias and partiality, including his alleged failure to recuse himself, could be disciplined administratively based on his rulings in BSC No. 2009-02 and Civil Case No. BCV-2005-94.

Whether Judge Garcia was administratively liable for undue delay in resolving the motion for reconsideration

Whether Judge Garcia’s delay in resolving Hebron’s motion for reconsideration of the September 18, 2009 Order constituted a sanctionable administrative wrong.
Whether...(Subscriber-Only)