A.M. No. RTJ-12-2331 - Magdadaro vs. Saniel, Jr.

Civil Case No. CEB-27778 was initiated on May 30, 2002 by Marcelino A. Magdadaro against Bathala Marketing Industries, Inc. (BMII) and other related parties for breach of contract with damages.
The dispute arose from a car accident involving complainant’s Nissan, insured under a comprehensive policy, where the damage assessment and repair process became a subject of contention.
Complainant submitted repair estimates after the accident at SM Megamall, obtained an inspection report from Nissan Distributors, Inc. (NDI), and later received a repair estimate from BMII which omitted certain damages (e.g., the radiator tank).
After repairs lasting about a month and payment of his share amounting to P9,120.50, complainant experienced recurring issues with the car’s engine overheating.
Subsequent inspection by Global Motors Cebu Distributors Corp. revealed that the radiator tank installed by BMII was not brand new but a reconditioned unit, leading to additional expenses for complainant.

Complainant submitted his memorandum on November 9, 2008, which was received on November 11, 2008 by RTC-Branch 20 of Cebu City.
Judge Bienvenido R. Saniel, Jr., presiding over RTC-Branch 20, rendered a Decision on December 28, 2009, dismissing the complaint for lack of cause of action.
Complainant filed a Notice of Appeal on February 22, 2010, with the same court; however, the appeal was acted upon only on December 2, 2010.

Frustrated by the prolonged delays in the resolution of Civil Case No. CEB-27778, complainant instituted an administrative complaint on October 17, 2011.
The administrative complaint alleged three main offenses by Judge Saniel:

Unreasonable delay in rendering a decision in the civil case.
Gross ignorance of the law in the interpretation of obligations under a comprehensive car insurance contract.
Bias and partiality, including errors in the transcription of the trial testimony and questionable procedural stamps on the decision.

Complainant further suggested that the decision might not have been authored by the respondent himself, based on anomalies found in the court records.

The administrative complaint was motivated by personal resentment as a reaction to the unfavorable decision in the civil case.
The filing was premature given that the appeal against his decision was still pending before the Court of Appeals.
Alleged delays in transmission and approval of the Notice of Appeal were due to staffing limitations.

The Office of the Court Administrator (OCA), in its Report dated March 7, 2012, recommended:

Re-docketing the complaint as a regular administrative matter.
Holding Judge Saniel liable for undue delay in both rendering the decision and processing the Notice of Appeal.
Imposing a fine of P20,000.00 along with a stern warning against future irregularities.

The court issued a Resolution on July 4, 2012 re-docketing the administrative complaint and requiring the parties to manifest their willingness to have the matter resolved on the basis of existing pleadings.
Subsequent manifestations were filed by complainant on September 24, 2012, and by respondent on October 8, 2012.

Whether Judge Saniel can be held administratively liable for the alleged undue and excessive delays in:

Whether his purported actions constitute gross ignorance of the law and display of bias or partiality in the administration of justice.

Appropriateness of Pursuing Administrative Remedies Simultaneously with Judicial Appeals

Whether it is procedurally proper to institute an administrative complaint against a judge when the judicial remedy (the appeal) is still pending.
Whether the administrative proceedings should be considered alternative to or cumulatively with the pending judicial review.

Whether the imposition of a fine (and potential suspension as provided under Section 9, Rule 140 of the Rules of Court) is appropriate given the circumstances of the delays.
Whether previous sanctions on Judge Saniel influence the penalty for this second infraction.