G.R. No. 121157 - Heirs of Maningding vs. Court of Appeals

Judge Balo was appointed Presiding Judge of Branch 44, Regional Trial Court (RTC), Surallah, South Cotabato.
Concurrently, he was designated Acting Presiding Judge of Branch 19, RTC Isulan, Sultan Kudarat.
On February 14, 2020, he became full-time Acting Presiding Judge of Branch 19, RTC Isulan.
On January 23, 2020, Judge Allan Edwin P. Boncavil was designated Acting Presiding Judge of Branch 44, RTC Surallah.
Judge Balo opted for retirement effective October 3, 2020.

On August 13, 2020, the Office of the Court Administrator (OCA) directed Judge Balo and his Branch Clerk of Court to submit a verified report regarding pending cases in Branch 44.
The request was in preparation for a judicial audit before his retirement.
Judge Balo initially submitted a report on September 7, 2020, but it was rejected for non-compliance with the required format.
Extensions to submit the report were granted twice upon requests by Judge Balo and his clerk.
The final verified report was received by the OCA only on October 29, 2020, nearly one month after Judge Balo’s retirement.

The OCA issued a Memorandum dated September 30, 2020, directing Judge Balo to explain delays in disposition of cases and pending incidents in Branch 44 within 10 days.
Judge Balo received this memorandum on October 2, 2020, a day before retirement.
The OCA extended the deadline for response to October 27, 2020.
On October 27, 2020, Judge Balo admitted delays in disposition of two criminal cases where judgments were not immediately promulgated after guilty pleas.
He attributed the delays to heavy workload and the COVID-19 pandemic.

The OCA found Judge Balo deficient for not requesting extensions and for acting without authority on cases in Branch 44 after his transfer.
The JIB concurred with the OCA, recommending fines for Gross Ignorance of the Law and Undue Delay in Rendering Decisions or Orders.
The JIB recommended penalties totaling fines equivalent to nine months’ salary.

The core issues: whether jurisdiction over the complaint remains post-retirement of Judge Balo, and whether he is administratively liable.
The Court recognized the continuing jurisdiction under specific conditions when disciplinary proceedings were initiated before retirement and the judge was given opportunity to explain.
The Court found delays in disposition and resolution of pending cases and incidents in Branch 44, detailing delays ranging from 8 months to over a year in multiple criminal and civil cases.
Judge Balo was found guilty of three separate counts of Gross Neglect of Duty: delays in criminal case judgments, delays in resolving criminal incidents, and delays in civil case incidents.
The charge for acting without authority in Branch 44 after transfer was dismissed for lack of jurisdiction due to absence of prior notice and opportunity to explain.

Does the Supreme Court retain jurisdiction over the administrative disciplinary proceedings despite Judge Balo’s optional retirement on October 3, 2020?

Did Judge Balo commit Gross Neglect of Duty by unduly delaying the resolution of cases and pending incidents in Branch 44, RTC Surallah?
Did Judge Balo commit Gross Ignorance of the Law by acting without authority on pending incidents in Branch 44 after being appointed full-time Acting Presiding Judge of Branch 19, RTC Isulan?