G.R. No. 9146 - People vs. Rampas

The administrative complaint was filed by the Office of the Court Administrator (OCA) against Judge Tingaraan U. Guiling, Officer-in-Charge Cleotilde P. Paulo, Process Server Gaudencio P. Sioson, and Sheriff Reyner de Jesus of RTC, Branch 109, Pasay City.
The complaint arose from the findings of a judicial audit and inventory of cases conducted from April 14 to 30, 2015, pursuant to Travel Order No. 42 dated April 13, 2015.

The audit revealed that Branch 109 had a total of 1,456 active cases, consisting of 409 criminal cases and 1,047 civil cases.
Detailed status/stage of proceedings were recorded, including:

Warrants/Summons, Arraignment, Preliminary Conferences/Pre-trials/JDR, Trials/Hearings, cases “For Compliance”, “No Action Taken”, “No Further Action/Setting”, “With Pending Motions/Incidents”, “Submitted for Decision”, “Decided/Withdrawn/Terminated”, “Dismissed”, “Archived”, “Suspended Proceedings”, and “Newly Filed”.

From May to August 2015, copies of orders, decisions, and various filings were forwarded by Branch 109 to the Court, highlighting numerous pending matters and delays in proceeding with several cases.

Lack of return of summons in a replevin case.
Incomplete criminal case folders missing Certificates of Arraignment.
Delayed submission of the Semestral Docket Inventory and the Monthly Report of Cases, with some records dating as far back as 2011 and 2014 respectively.
Outdated and unupgraded general docket books.
Pre-trial orders signed solely by the Presiding Judge.

Despite the Office of the Solicitor General filing motions to obtain copies of petitions and relevant documents, cases proceeded without compliance.
In several cases, issues arose from substituted service of summons:

Process Server Gaudencio Sioson availed of substituted service when the respondent was unavailable.
Sheriff Reyner de Jesus also used substituted service but his returns lacked detailed information regarding the circumstances of service, including the attempts made, the inquiries conducted, and the identification of the person served.

Several summons were served with general statements, failing to detail the legal requirements as established by precedents like the Manotoc case.
Some orders sent to petitioners were returned by the post office with indications that the petitioners were not residents of the area.

Judge Guiling was observed prioritizing the hearing and swift decision of annulment cases, which were completed within a very short span of time despite issues in service of summons.
A non-court staff member identified as “Mang Boy” (Mr. Adolf Mantala), later revealed as the personal secretary of Sheriff de Jesus, was present in the court from April 14 to 29, 2015, and was seen engaging with court staff.
There were concerns about the handling and custody of court records, notably with records found in the trunk of the sheriff's car. Both Sheriff de Jesus and Officer-in-Charge Cleotilde Paulo provided insufficient explanations regarding these anomalies.

Taking prompt action on pending motions/incidents and submitted cases for decision.
Rendering judgment within the mandated period, especially considering the non-compliance in service requirements for cases involving annulment of marriage before critical documents (OSG Notice of Appearance and Report on Collusion) were received.
Delays in submission of the Monthly Report of Cases and the Semestral Docket Inventory.

The OCA recommended the re-docketing of the judicial audit report as an administrative complaint against all respondents.
Specific penalties recommended included:

For Judge Guiling: Guilty of gross dereliction of duty, inefficiency, and incompetence with a recommended fine of P50,000.00 (to be deducted from his retirement benefits), and an order to expedite remaining pending cases.
For Officer-in-Charge Cleotilde Paulo: Suspension for six (6) months without salaries and allowances.
For Sheriff Reyner de Jesus: A fine of P20,000.00.
For Process Server Gaudencio Sioson: A fine of P5,000.00.

Whether the administrative lapses and delays in the docket and record management by Judge Guiling and his staff constitute gross dereliction of duty, gross inefficiency, and gross incompetence under judicial administrative rules.

Whether the irregularities in the service of summons—especially in sensitive cases such as annulment of marriage and recognition of foreign divorce—violate established jurisprudence and procedural requirements, including those set forth in the Manotoc case.

Whether the respondents provided adequate and sufficient explanations for their failures, such as the delay in the submission of monthly reports and the improper handling of court records.

Whether the sanctions recommended by the OCA (fines, suspension, and other disciplinary measures) are proper, justified, and proportionate given the gravity of the offenses committed.