Title
Dr. Julian L. Espiritu, Jr., represented by Rubenito R. Del Castillo, vs. Presiding Judge Santiago M. Arenas, Regional Trial Court of Quezon City
Case
A.M. No. RTJ-21-014
Decision Date
Dec 5, 2023
Judge Santiago M. Arenas was found guilty of simple neglect of duty for undue delay in resolving a motion for execution, resulting in a PHP 120,000.00 fine.
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Case Digest (A.M. No. RTJ-21-014)

Facts:

  • Dr. Julian L. Espiritu, Jr. filed a complaint against Presiding Judge Santiago M. Arenas of the RTC of Quezon City, Branch 217.
  • The complaint, dated December 5, 2023, alleged gross ignorance of the law and inefficiency related to Civil Case No. Q-00-41263.
  • Judge Arenas issued a decision on July 13, 2010, favoring Dr. Espiritu, awarding him 5/6 of the disputed property.
  • The decision was appealed and affirmed by the Court of Appeals and the Supreme Court, becoming final.
  • Execution proceedings were remanded to the RTC, and Dr. Espiritu filed a Motion for Execution on July 9, 2015.
  • Judge Arenas resolved the motion nearly three years later, on July 6, 2018, which Dr. Espiritu claimed was an undue delay.
  • Judge Arenas entertained various motions from the defendants, which Dr. Espiritu argued reopened a decided case.
  • Judge Arenas defended himself by stating the delay was not entirely his fault and that he had cautioned the defendants.
  • Judge Arenas retired on October 27, 2020.
  • The OCA recommended dismissing the gross ignorance charge but found him liable for undue delay, suggesting a fine of PHP 15,000.

Issue:

  • (Unlock)

Ruling:

  • The Court dismissed the charge of gross ignorance of the law against Judge Arenas.
  • The Court found Judge Arenas administratively liable for simple negle...(Unlock)

Ratio:

  • The Court upheld the OCA's recommendation to dismiss the gross ignorance charge, stating that Judge Arenas acted within his judicial discretion by entertaining subsequent pleadings.
  • Errors in his rulings should have been addressed through judicial remedies, not an administrative complaint.
  • Regarding undue delay, the Court agreed with the OCA that Judge Arenas neglected his duty due to significant delay...continue reading

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