A.M. No. 04-5-118-MTCC - Re: Compliance of Judge Maxwel S. Rosete

1. Request for Reassignment:

On 16 September 2002, Judge Maxwel S. Rosete, Presiding Judge of the Municipal Trial Court in Cities (MTCC) of Santiago City, Isabela, wrote to Deputy Court Administrator (DCA) Jose P. Perez requesting to be designated as an acting judge in any vacant sala within Metro Manila. He claimed that he had "only a handful of cases pending for trial before his sala numbering to a little more than one hundred."

2. Comments from Executive Judges:

DCA Perez sought comments from Judge Ruben Plata (Executive Judge of the Municipal Circuit Trial Court, Branch 1, Santiago City) and Judge Fe Albano-Madrid (Executive Judge of the Regional Trial Court, Branch 21, Santiago City). Both judges offered no objection to Judge Rosete's request.

3. OCA's Findings:

In a memorandum dated 20 January 2003, DCA Perez recommended denying Judge Rosete's request. The OCA records showed that as of October 2002, Judge Rosete had 326 pending cases in Branch 2, MTCC of Santiago City, and 212 pending cases in the Municipal Trial Court (MTC) of Cordon, Isabela, where he was the Acting Presiding Judge. There were no vacant courts in Metro Manila, and Judge Rosete's record did not show exemplary performance warranting reassignment.

4. Chief Justice's Memorandum:

On 24 February 2003, the Chief Justice denied Judge Rosete's request and directed him to show cause why no disciplinary action should be taken against him for misrepresenting the volume of pending cases. Judge Rosete was required to submit a detailed list of pending cases within 30 days.

5. Compliance and OCA's Observations:

Judge Rosete submitted a docket inventory on 28 April 2003, showing 254 pending cases in Branch 2, MTCC of Santiago City, and 105 cases in the MTC of Cordon, Isabela. The OCA noted a significant decrease in pending cases but found that Judge Rosete's initial statement was still misleading.

6. Slow Movement of Cases:

The OCA observed that many cases in Judge Rosete's courts had been pending for years, with some filed before 2000 still unresolved. The OCA recommended a fine of P10,000 for the slow movement of cases and noted that Judge Rosete had previously been fined in an administrative case.

Dishonesty and Lack of Candor:
- A member of the Judiciary must exhibit honesty, fairness, and good faith in all dealings, especially with the Court. Misrepresentation, even if not directly related to litigants, undermines the integrity of the judicial system. Dishonesty is anathema to the role of a magistrate, who is expected to uphold the highest moral standards.
Prompt Disposition of Cases:
- Judges are mandated to resolve cases promptly and within the required periods. Delays in case disposition amount to a denial of justice and erode public confidence in the Judiciary. Judges must ensure that the mandatory periods under the Rules of Court are strictly observed.
Due Process:
- While Judge Rosete's actions warranted disciplinary action, the Court emphasized the importance of due process. He was given an opportunity to explain the causes of the delay in case disposition before any further sanctions were imposed.
Accountability:
- Judges are accountable not only for their decisions but also for their conduct and the efficient management of their courts. Any act of dishonesty or inefficiency is subject to administrative sanctions to maintain the integrity of the Judiciary.