A.M. No. RTJ-21-014 - Dr. Julian L. Espiritu, Jr., represented by Rubenito R. Del Castillo, vs. Presiding Judge Santiago M. Arenas, Regional Trial Court of Quezon City

Complainant Dr. Julian L. Espiritu, Jr., represented by Rubenito R. Del Castillo, filed an administrative Complaint against Presiding Judge Santiago M. Arenas of RTC Quezon City, Branch 217.
The complaint charged Judge Arenas with Gross Ignorance of the Law and Gross Inefficiency in connection with Civil Case No. Q-00-41263 (“Julian Espiritu, Jr. v. Lily Ann Espiritu-A-Misa and Jose Mari Misa”).
The subject case was raffled to Judge Arenas’ sala, and after due proceedings, he promulgated a decision on July 13, 2010 in favor of the complainant, awarding 5/6 of the disputed property.

The decision was appealed to the Court of Appeals and later to the Supreme Court, where Judge Arenas’ decision was essentially affirmed.
Following finality, the case records were remanded to the RTC for execution proceedings.
The complainant filed a Motion for Execution as early as July 9, 2015; however, the resolution was delayed and only finalized through an Order issued on July 6, 2018.
Complainant contended that the prolonged delay in resolving the motion for execution justified administrative sanctions against Judge Arenas.

The complainant’s motion for execution, filed on July 20, 2015, was resolved by an Order on August 31, 2016, with the Writ of Execution issued on August 18, 2017.
The delay was attributable not to his own inaction but to subsequent pleadings and motions by the parties and multiple resettings of hearings.
His permitting of additional pleadings (including testimony from the complainant and the defendants’ mother) was an exercise of judicial discretion, not grounds for a charge of gross ignorance of the law.

The complaint also involved a separate incident concerning the defendants’ Motion to Enjoin the Implementation of the Writ of Execution, where the final pleading (the Rejoinder) was filed on December 7, 2017, but was only resolved seven months later.
During the pendency of the case, Judge Arenas compulsorily retired from the Judiciary on October 27, 2020.

The Office of the Court Administrator (OCA) issued a Memorandum on January 4, 2021, with the following key recommendations:

Dismiss the charge of gross ignorance of the law, noting that such conduct falls within judicial discretion.
Find Judge Arenas administratively liable for undue delay in resolving motions, particularly for the defendants’ Motion to Enjoin the Implementation of the Writ of Execution.
Impose a fine of PHP 15,000.00 for the delay in rendering an order associated with the execution proceedings.

The OCA explained that any delay perceived in the resolution of the complainant’s Motion for Execution could not be solely ascribed to Judge Arenas due to intervening pleadings and motions by the parties.

The Court determined that the case should be resolved under the framework of Rule 140 of the Rules of Court, as amended by A.M. No. 21-08-09-SC effective April 3, 2022.
The retroactive effect of Section 24 of the Rules ensured that pending and future administrative disciplinary cases involving members of the judiciary, including this matter, would be governed by the amended provisions.
The applicable constitutional provision (Article VIII, Section 15(1)) mandates that lower courts resolve matters within three months from the date of submission for resolution.

Whether Judge Arenas’ supervening compulsory retirement affected the Court’s jurisdiction and the continuation of the administrative proceeding.
Whether the administrative proceeding may be instituted and sustained when the complaint was filed during the respondent’s incumbency despite his subsequent retirement.

Whether Judge Arenas should be held liable for the alleged Gross Ignorance of the Law for entertaining subsequent pleadings and reopening matters which were already final and executory.
Whether the delay in resolving the execution-related motions, particularly the defendants’ Motion to Enjoin the Implementation of the Writ of Execution, constitutes undue delay attributable to Judge Arenas.
Determination of the appropriate classification of the negligence—whether it amounts to gross neglect or simple neglect of duty in the performance or non-performance of official functions.

Given the established administrative liability, what penalty should be imposed on Judge Arenas, especially considering his prior disciplinary record and his retirement status.