Title
Re: Elvira N. Enalbes
Case
A.M. No. 18-11-09-SC
Decision Date
Jan 22, 2019
Former Chief Justice Teresita J. Leonardo-De Castro faced administrative charges for alleged gross inefficiency, misconduct, and delay in resolving petitions. The Supreme Court dismissed the complaint, ruling no prima facie case existed, emphasizing judicial discretion and the directory nature of case resolution timelines.

Case Digest (A.M. No. 18-11-09-SC)

Facts:

  • Nature of the Complaint
    • Complainants Elvira N. Enalbes, Rebecca H. Angeles, and Estelita B. Ocampo filed a Complaint-Affidavit against former Chief Justice Teresita J. Leonardo-De Castro.
    • The charges included gross ignorance of the law, gross inefficiency, gross misconduct, gross dishonesty, and conduct prejudicial to the best interest of the service.
  • Background of the Case
    • On September 4, 2012, Spouses Eligio P. Mallari and Marcelina I. Mallari filed a Petition for Mandamus and Prohibition with Prayer for Temporary Restraining Order before the Supreme Court, docketed as G.R. No. 203063.
    • The Petition was filed against two divisions of the Court of Appeals: the First Division and the Special Former Fourth Division of Five, involving several justices including their presiding justices.
    • On January 25, 2013, the Mallari Spouses filed a Petition for Review on Certiorari, docketed as G.R. No. 204743, against the Philippine National Bank and the Special Former Fourth Division of the Court of Appeals.
    • Both Petitions were assigned to the Supreme Court’s First Division and raffled to then Chief Justice De Castro.
  • Allegations of Delay and Misconduct
    • Complainants argued that despite the lapse of more than five years, respondent failed to decide on both petitions of the Mallari Spouses.
    • They maintained this delay violated the spouses' constitutional right to the speedy disposition of cases.
    • Further, complainants accused the respondent of graft and corruption for allegedly giving undue benefits to the Philippine National Bank through manifest partiality, bad faith, or negligence, thereby causing undue injury to the Mallaris.
  • Procedural Posture
    • The administrative complaint was brought before the Supreme Court to determine the administrative liability of former Chief Justice De Castro.

Issues:

  • Whether the failure of former Chief Justice Teresita J. Leonardo-De Castro to promptly decide the petitions of the Mallari Spouses constitutes:
    • Gross ignorance of the law;
    • Gross inefficiency;
    • Gross misconduct;
    • Gross dishonesty; and
    • Conduct prejudicial to the best interest of the service.
  • Whether the delay violated the constitutional right to the speedy disposition of cases.
  • Whether such delay warrants administrative sanctions, including dismissal or other penalties.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.