A.M. No. MTJ-05-1603 - Sevilla vs. Quintin

Complainant: Jaime R. Sevilla, brother of the accused, who filed the complaint alleging judicial misconduct.
Respondent: Judge Edison F. Quintin of Malabon Metropolitan Trial Court (MeTC) Branch 56.
Alleged acts by the respondent include:

Granting fifteen indiscriminate and arbitrary postponements in criminal cases (CC Nos. 5300-96 to 5503-96).
Demonstrating gross ignorance of the law and manifest partiality by enabling dilatory proceedings.
Allowing a belated, verbal “manifestation” for filing a demurrer to evidence contrary to procedural requirements.

The complaint was filed on June 2, 2004, with the Office of the Court Administrator (OCA).
The complainant cited violations of:

Batas Pambansa Blg. 22.
Canon 1, Rule 1.0 of the Code of Judicial Conduct.
Section 1, Rule 135 of the Revised Rules of Court and the spirit of the 1991 Revised Rules on Summary Procedure, as amended by A.M. No. 00-11-01-SC.
Section 3(e) of Republic Act No. 3019 concerning corrupt practices.

Cases were filed as early as 1996 and initially handled by a previous presiding judge.
The new presiding judge set the cases for trial on March 1, 1999, with the prosecution filing its formal offer of evidence on September 30, 1999.

A destructive fire on July 22, 2000, gutted the court records, affecting all files beyond November 1999.
A petition for the reconstitution of cases was filed on December 12, 2000, with a subsequent hearing on January 9, 2001.

The cases were set for hearing on August 3, 2001, and subsequently reset on numerous occasions—up to eight reschedulings confirmed by the private prosecutor’s signature.
Specific postponements were attributed to:

Absences of either the private or public prosecutor and/or defense counsel.
Two notable instances where the private prosecutor objected (September 19, 2002 and August 7, 2003), although the court allowed the resetting pending the accused’s opportunity to present evidence.
Additional resets were caused by sickness of the public prosecutor, natural calamities (flood), and administrative adjustments.

On December 16, 2003, the respondent allowed a belated verbal motion from defense counsel to file a demurrer to evidence, despite procedural rules requiring a formal, timely filing.
This act was later emphasized as contrary to Section 23, Rule 119 of the Rules of Criminal Procedure.

The OCA observed that the respondent had been overly liberal in granting postponements, some without properly questioning absences or ordering explanations from defense counsel.
OCA criticized the failure to rule on the prosecution’s formal offer of evidence for over eight months prior to the fire incident, and again the belated verbal manifestation for filing a demurrer more than four years after the prosecution rested its case.
Based on these findings, the OCA recommended a fine of Twenty Thousand Pesos (₱20,000.00) on grounds of gross ignorance of the law and violation of the Code of Judicial Conduct.

The court’s schedule constraints in Branch 56, which conducts criminal hearings only twice a week in the mornings (the only schedule available to the public prosecutor).
The complainant’s prior tolerance of the private prosecutor’s absences and the repeated resettings despite being ready for trial.
The respondent’s defense that certain postponements were justified by uncontrollable events and the need to allow a final opportunity for the accused to present evidence.

Whether the respondent’s repeated, indiscriminate postponements constitute gross ignorance of the law and abuse of judicial discretion.

Consideration of whether granting fifteen postponements was excessive and prejudicial to the administration of justice.

Whether the respondent’s actions violated the Code of Judicial Conduct and applicable procedural rules, including:

Rule 1.02, which mandates the prompt administration of justice.
Rule 3.05, which requires the disposition of the court’s business within prescribed periods.

Whether the grant of a belated, verbal motion to file a demurrer to evidence, despite procedural time limits and requirements under Section 23, Rule 119 of the Revised Rules, was proper.

Examination of whether the absence of timely objection by the prosecution justified or mitigated this error.

To what extent the uncontrollable circumstances such as the courthouse fire, absences of counsel, and scheduling limitations mitigate the respondent’s misconduct.

Whether the exercise of judicial discretion in this case exceeded the bounds of acceptability, thus warranting disciplinary sanction and monetary fine.