G.R. No. L-35154 - Filart vs. Commission on Elections

The judicial audit was conducted on March 12–13, 2013, at RTC Branch 20 in Cagayan de Oro City, Misamis Oriental under then Presiding Judge Bonifacio M. Macabaya.
The audit examined 573 cases and identified significant delays and irregularities:

Sixty-nine (69) cases submitted for decision exceeded the 90-day period mandated by paragraph 1, Section 15, Article VIII of the 1987 Constitution.
Thirty-three (33) cases with pending incidents had not been resolved within the reglementary period.
One hundred fifty-five (155) cases were noted as dormant or unacted upon over an extended period.

An Order dated November 22, 2011, required the accused to secure a new bail bond within five days despite the existing bond having not been properly maintained, contrary to Sec. 2(a) of Rule 114 of the Revised Rules of Criminal Procedure.

In Criminal Cases involving People v. Alba (Nos. 2000-260, 2000-316, 2002-098, and 2002-100):

Twin Orders issued on September 26, 2006, directed issuance of arrest warrants and mandated ex parte hearings by the Branch Clerk—a measure violating standard criminal procedure and established jurisprudence.

The RTC’s February 2013 report contained omissions and inaccuracies, including erroneous case classifications and unpublished unresolved motions, undermining the reliability of official records.
Docket books for civil cases were not updated regularly; defects were noted in the docket inventory for July–December 2012, and crucial records (judgment book, book of entries, execution book) were missing.

Judge Macabaya’s wife, a non-court employee, was regularly present and actively participated during the audit, including handing over case records and interacting with court staff.
Despite concerns raised by the audit team, Judge Macabaya claimed full control over his wife’s actions and acknowledged her “assistance” in overseeing administrative functions.

On April 4, 2013, the Clerk of Court submitted an Action Plan (signed by Judge Macabaya) for April 2013 to April 2014 aimed at remedying the audit exceptions.

The Action Plan was criticized for its single strategy and inflexible time frame, leading the audit team to recommend specific revisions with measurable benchmarks.

Subsequent communications between Judge Macabaya and the Office of the Court Administrator (OCA):

In letters dated March 14, 2014, and May 19, 2014, the OCA reiterated directives for Judge Macabaya to explain delays in resolving pending cases and to supply copies of corresponding orders, decisions, and resolutions.
Judge Macabaya’s responses were piecemeal; he submitted copies of some orders and decisions without the required explanations, often after significant delays and even after the deadline had passed.

Owing to his repeated failure to fully comply with the directives, on December 1, 2014, the Court resolved to take disciplinary action:

Judge Macabaya was ordered to show cause why no disciplinary action should be taken for his non-compliance in deciding, resolving, and acting upon cases beyond the mandated period.
He was also relieved of his judicial and administrative functions, with the exception that he must still resolve pending cases.
His salaries and benefits were to be withheld pending further orders.
Acting Presiding Judge Gil G. Bollozos was designated to take over some administrative functions and case management responsibilities.

On February 18, 2015, Judge Macabaya filed a Motion for Reconsideration/Explanation claiming:

That the penalties were imposed without a formal administrative charge or investigation, thus violating his right to due process.
That some of the unresolved cases were inherited and still within the permissible extension period, partly due to challenges such as a fire at the Hall of Justice.

The Supreme Court, after reviewing Judge Macabaya’s explanations and supplemental submissions, found his arguments unconvincing and self-serving in light of the clear and well-documented audit findings.

The primary legal issue is whether Judge Bonifacio M. Macabaya is guilty of:

Gross misconduct due to his repeated failure to comply with directives of the Office of the Court Administrator and the Supreme Court.
Gross ignorance of the law and of the rules of procedure, as evidenced by the issuance of defective orders and improper case handling.

Dismissal from the service and forfeiture of retirement benefits (except for accrued leave credits),
With prejudice to any future reinstatement in any branch of government, including government-owned and controlled corporations.