Facts:

The administrative case at hand involves a complaint filed by Aero Engr. Darwin A. Reci against Court Administrator Jose Midas P. Marquez and Deputy Court Administrator Thelma C. Bahia. The complaint, dated August 20, 2016, alleges Gross Negligence and Dereliction of Duty concerning the handling of Criminal Case No. 05-236956, which involved Reci's brother, PO2 Dennis Azuela Reci. The case, presided over by Judge Amelia Tria Infante at the Regional Trial Court of Manila, Branch 9, involved charges of Qualified Trafficking in Persons under Republic Act No. 9208, also known as the Anti-Trafficking in Persons Act of 2003. After PO2 Reci was convicted, his counsel filed a Notice of Appeal. However, three years later, the case records had not been transmitted to the Court of Appeals. It was only after Reci's persistent inquiries that the records were finally sent. The complainant expressed diss...

Facts:

Background of the Case

• The administrative case arose from a complaint filed by Aero Engr. Darwin A. Reci (complainant) against Court Administrator Jose Midas P. Marquez (CA Marquez) and Deputy Court Administrator Thelma C. Bahia (DCA Bahia) for Gross Negligence and Dereliction of Duty.
• The complainant is the older brother of PO2 Dennis Azuela Reci (PO2 Reci), who was convicted in Criminal Case No. 05-236956 for Qualified Trafficking in Persons under Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003).

Allegations of the Complainant

• PO2 Reci’s counsel filed a Notice of Appeal before the Regional Trial Court (RTC) of Manila, Branch 9, presided by Judge Amelia Tria Infante.
• The complainant discovered that, three years after the Notice of Appeal was filed, the case records had not been transmitted to the Court of Appeals.
• The transmittal of the records occurred only after the complainant prodded the court.
• The complainant argued that the delayed transmittal resulted in administrative sanctions (reprimand and warning) against the RTC clerk of court and court stenographer, but no penalties were imposed on Judge Infante.
• The complainant accused CA Marquez and DCA Bahia of Gross Negligence and Dereliction of Duty for failing to monitor Judge Infante’s alleged incompetence in the timely transmittal of the case records.

Issue:

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Ruling:

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Ratio:

1. Definition of Gross Negligence and Dereliction of Duty:

   • Gross neglect of duty refers to a flagrant and culpable refusal or unwillingness to perform a duty, characterized by a conscious indifference to consequences.
   • Simple neglect of duty involves the failure to give proper attention to a task, resulting from carelessness or indifference.

2. Quantum of Evidence Required:

   • The standard of proof for administrative liability is substantial evidence, which is relevant evidence that a reasonable mind might accept as adequate to justify a conclusion.

3. Presumption of Regularity:

   • Public officials, including CA Marquez and DCA Bahia, are presumed to have performed their duties regularly unless proven otherwise.

4. Application to the Case:

   • The complainant’s allegations were unsupported by evidence. Absent proof of negligence or dereliction of duty, the complaint could not be sustained.
   • The Court emphasized that the burden of proof lies with the complainant, who failed to meet this burden.

Conclusion:

• The Court dismissed the complaint against CA Marquez and DCA Bahia, upholding the presumption of regularity in the performance of their duties.