Case Digest (A.M. No. RTJ-12-2331)
Facts:
Marcelino A. Magdadaro v. Judge Bienvenido R. Saniel, Jr., A.M. No. RTJ-12-2331 (Formerly OCA I.P.I. No. 11-3776-RTJ), December 10, 2012, First Division, Leonardo-De Castro, J., writing for the Court.Complainant Marcelino A. Magdadaro filed an administrative complaint against respondent Judge Bienvenido R. Saniel, Jr., then presiding judge of the Regional Trial Court (RTC), Branch 20, Cebu City, alleging unreasonable delay, gross ignorance of the law, and bias in connection with Civil Case No. CEB-27778 (Magdadaro v. Bathala Marketing Industries, Inc., et al.), an action for breach of contract with damages originally filed May 30, 2002.
In the underlying civil case, Magdadaro alleged damage to his Nissan car and deficiencies in repairs performed by Bathala Marketing Industries, Inc. (BMII) and others; he submitted repair estimates and claims to his insurer PNB-GICI and pursued repairs and replacements, incurring expenses. After trial, the RTC (Branch 20) directed memoranda, and Magdadaro filed his memorandum, received November 11, 2008. The trial court issued a Decision dismissing the complaint on December 28, 2009.
Magdadaro filed a Notice of Appeal on February 22, 2010; however, the trial court acted on that notice and approved it only on December 2, 2010, resulting in an approximately ten-month delay in transmitting the records. Frustrated by what he characterized as undue delay and alleged errors in the trial court decision (including asserted misquotes in the Decision and alleged mistranscriptions in the TSN), Magdadaro filed the present administrative complaint on October 17, 2011, contending that the judge also displayed gross ignorance of the law and bias in resolving the merits.
Respondent Judge Saniel answered that the administrative complaint was premature because the appealed judgment was pending before the Court of Appeals (docketed SP Civil Case No. R-1105), and explained the delay in acting on the Notice of Appeal by understaffing and workload; he did not, however, address the more-than-one-year delay in rendering the Decision after submission. The Office of the Court Administrator (OCA) investigated and, in its March 7, 2012 Report, recommended re-docketing as a regular administrative matter and that Judge Saniel be held liable for undue delay and fined Twenty Thousand Pesos (P20,000.00) with a stern warning.
The Supreme Court issued a Resolution re-docketing the complaint as a regular administrative matter and required the parties to state whether they would submit the case on the pleadings; both parties filed manifestations. The Court consid...(Pro-only)
Issues:
- Is the administrative complaint alleging judicial error and bias premature or improper while the appealed judgment is still pending before the Court of Appeals?
- Was respondent Judge Saniel administratively liable for undue delay in rendering a decision and in transmitting the records/acting on the Notice of Appeal, and wh...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)