Case Digest (A.M. No. 14-10-339-RTC, RTJ-16-2446)
Case Digest (A.M. No. 14-10-339-RTC, RTJ-16-2446)
Facts:
Office of the Court Administrator v. Judge Marybelle L. Demot-Marinas, A.M. No. 14-10-339-RTC; A.M. No. RTJ-16-2446 [Formerly A.M. No. 14-3-53-RTC], March 07, 2017, Supreme Court En Banc, Per Curiam.This administrative matter consolidates two complaints against Judge Marybelle L. Demot-Marinas, Presiding Judge, RTC Branch 8, La Trinidad, Benguet: (1) an audit-initiated complaint from the Court Management Office's judicial audit of Branch 8 conducted March 30–April 12, 2014 (processed as A.M. No. 14-10-339-RTC); and (2) an indorsement-driven complaint originating from letters by Ms. Lilia Nugal‑Koh seeking the Court’s intercession for resolution of Special Proceedings No. 95‑SP‑0086 (processed as A.M. No. RTJ‑16‑2446). The Office of the Court Administrator (OCA) acted as complainant.
The judicial audit found Branch 8 with a caseload of 309 cases (135 criminal, 174 civil), including 157 cases already submitted for decision beyond the reglementary period. The OCA recommended directives including that Judge Demot‑Marinas cease hearing new matters until she decided 150 specified cases (45 criminal, 105 civil), dispose of certain cases then within the reglementary period, and resolve pending motions/incidents in 17 cases; the OCA also proposed withholding her salary and designating an assisting judge. The Court adopted the OCA’s findings and recommendations on April 7, 2015.
Separately, repeated indorsements from the Office of the Chief Justice and the Office of the Deputy Court Administrator (March–September 2013) sought Judge Demot‑Marinas’ comment on Ms. Nugal‑Koh’s complaint that Special Proceedings No. 95‑SP‑0086 had been submitted for decision since 2003. The OCA found repeated non‑compliance with directives and treated the matter as a formal administrative complaint for insubordination, inefficiency and neglect of duty. The OCA later recommended consolidation of the two matters and, in a December 1, 2015 memorandum, sought a finding of guilt for grave misconduct, insubordination and gross inefficiency with dismissal from service and forfeiture of benefits.
Judge Demot‑Marinas submitted a June 4, 2015 letter apologizing and admitting fault but offered no substantive explanation; she also signified an intention to resign. The OCA verified partial compliance in some cases but confirmed many matters remained undecided, some since 2002–2003. The Court consolidated the administrative complaints on February 17, 2016 and, after considering OCA recommendations, rendered the present En Banc decision on March 7, 2017.
Issues:
- Is Judge Marybelle L. Demot‑Marinas administratively liable for gross inefficiency and/or gross misconduct for her delay in deciding cases and for disregarding directives of the OCA and the Court?
- If liable, what penalty should be imposed?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)