Facts:

This case revolves around the administrative complaint filed by Alfredo P. Tadiar against Municipal Judge Simeon Caces of Bauang, La Union. The case emerged from two criminal complaints for grave oral defamation filed on November 6, 1967, by the chief of police against Consuelo Balanon in the municipal court of San Fernando, La Union. The complainants were Maria F. Tadiar, Alfredo F. Tadiar, and Esther Tadiar-Bautista, and the cases were designated as Criminal Cases Nos. 7172-3. Due to circumstances, Judge Pedro O. Arciaga of San Fernando inhibited himself from the case, leading to the appointment of Judge Simeon Caces by the Court of First Instance of La Union to try the cases via Administrative Order No. 101 issued on December 9, 1967.

After the prosecution presented its evidence, the accused filed a motion to dismiss—known as a demurrer to the evidence—on December 23, 1969. The prosecutor opposed this motion, and both documents were submitted for resolution by Judge Caces on

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Facts:

Filing and Assignment of Cases

• In November 1967, two criminal complaints for grave oral defamation were filed in the municipal court of San Fernando, La Union, against Consuelo Balanon.
• The offended parties were Maria F. Tadiar, Alfredo F. Tadiar, and Esther Tadiar-Bautista, with the complaints initiated by the chief of police.
• Incumbent Judge Pedro O. Arciaga inhibited himself from the case, prompting the reassignment of the case to municipal judge Simeon V. Caces of Bauang, La Union, as designated by Judge Javier Pabalan of the Court of First Instance of La Union.

Proceedings and Submission of Motion to Dismiss

• After the prosecution completed its presentation of evidence, Consuelo Balanon filed a motion to dismiss (demurrer to the evidence) on December 23, 1969.
• The motion, along with the opposition from the Special Counsel, was mailed and was deemed submitted for resolution on January 5, 1970.
• On February 24, 1970, the stenographic transcript, taken by Rosie Munar, was received by Judge Caces upon his request, but he failed to obtain the complete records from the Municipal Court of San Fernando.

Delay, Negligence, and Judicial Oversight

• Despite having the transcript and his own notes in possession, Judge Caces did not personally retrieve or secure the records of the two criminal cases from the clerk of the court in San Fernando.
• Alfredo F. Tadiar, later serving as the municipal judge of San Fernando and a private prosecutor in the cases, repeatedly reminded Judge Caces about the pending motion through a letter dated February 19, 1973.
• In response, Judge Caces eventually sent an order of acquittal dated July 20, 1971 on March 13, 1973; however, this order was never filed in the official records of the criminal cases.

Deficiencies in Handling the Order of Acquittal

• The order acquitting Consuelo Balanon was neither filed in the case records nor properly furnished to all necessary parties.
• Only the accused received a copy of the order promptly after its issuance, while the prosecution did not receive it until well after the resolution, and the clerk of court was not provided with the original for docketing.
• This failure in proper filing and service disrupted the formal adjudication process and created procedural ambiguities regarding the disposition of the cases.

Testimony and Admission of Negligence

• During testimony, Judge Caces admitted to a prolonged delay in resolving the motion and acknowledged that he had “forgotten” about the case due to mishandling and cumbersome separation of case files.
• His testimony revealed that he intentionally withheld furnishing the copies of his resolution to the prosecution, claiming he awaited the complete records to possibly amend his decision if necessary.
• He further asserted that factors such as his concurrent responsibilities in other municipalities contributed to his inability to promptly resolve the motion.

Prior Disciplinary History and Reputation

• Judge Caces had a blemished record, with previous administrative cases dating back to the 1950s, including charges of undue delay, negligence, abuse of discretion, and favoritism in separate criminal and administrative proceedings.
• Prior disciplinary actions had been taken against him, such as reprimands and warnings for similar acts of dereliction, which called into question his competence and dedication to judicial duties.
• His record indicated that he was not previously unaware of his responsibilities, despite having been repeatedly cautioned against such irregularities.

Investigation and Administrative Complaint

• The scandalous delay in resolving the motion to dismiss and the failure to furnish the order to the prosecution led Judge Tadiar to file an administrative complaint against Judge Caces, charging him with dereliction of duty and violation of section 5 of the Judiciary Law.
• Judge Antonio G. Bautista’s investigation found that Judge Caces’ neglect, including relying on the clerk of court to provide the records, constituted a transgression of judicial protocols (notably, Circular No. 19, February 17, 1968).
• Based on his extensive record of negligence and the specific mishandling of the Balanon cases, the investigation recommended disciplinary measures, ultimately leading to his dismissal from the position.

Issue:

• Whether Judge Caces’ prolonged delay in resolving the motion to dismiss (over eighteen months after submission) constituted a failure to perform his judicial duties within the mandated time frame.
• Whether his failure to secure and file the complete records—including failing to furnish the original resolution to the clerk of court and the prosecution—resulted in a violation of procedural due process.
• Whether the explanation provided by Judge Caces, which shifted blame onto the clerk of court, sufficiently justified his inexcusable act of negligence.
• Whether his prior disciplinary record, marked by previous charges of negligence and abuse of discretion, should have accentuated the findings against him in the present case.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)