Title
Tiongco vs. Pedronio
Case
A.M. No. RTJ-03-1763
Decision Date
Apr 24, 2003
Judge Florentino P. Pedronio is found guilty of undue delay in rendering a decision and erroneous application of the law, resulting in a fine of P10,000, in the case of Tiongco v. Pedronio.
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Case Digest (A.M. No. RTJ-03-1763)

Facts:

  • The case involves an administrative complaint against Judge Florentino P. Pedronio of the Regional Trial Court, Branch 28, Iloilo City.
  • The complainant, Jose B. Tiongco, accused the respondent of grave abuse of discretion, gross incompetence, and inefficiency amounting to ignorance of the law and conduct unbecoming of a judge in connection with four criminal cases where Tiongco was the defense counsel.
  • The specific charges against Judge Pedronio are as follows:
    1. He failed to decide the case of People v. Baylon for Frustrated Homicide within the reglementary three-month period.
    2. He erroneously applied the law in the case of People v. Mahilum, resulting in the prolonged imprisonment of the accused.
    3. He refused to inhibit himself from rendering judgment in the case of People v. Sagutier, despite a motion from Tiongco and a previous order stating that the decision should be rendered by Judge Rene Honrado.
    4. He lacked mastery and command of the English language, as evidenced by his refusal to argue with Tiongco in open court and repeatedly ordering him to put his arguments in writing.
  • In his defense, Judge Pedronio explained that the delay in deciding People v. Baylon was not his fault as he assumed office after the case was submitted for decision. He also argued that the penalty he imposed in People v. Mahilum was based on the applicable law and that Tiongco misunderstood it. He denied the allegations of lacking mastery of the English language.
  • After evaluating the case, the Office of the Court Administrator (OCA) found that Judge Pedronio misapplied the Mabunay ruling, which resulted in the delay of the promulgation of People v. Baylon. However, the OCA also noted that the delay prior to February 7, 2002, was due to repeated rescheduling of the promulgation, which was not entirely within Judge Pedronio's control. The OCA recommended a reprimand for the delay in promulgation and the improper application of the Mabunay ruling.
  • Regarding the charge of gross ignorance of the law, the OCA stated that it is a judicial matter and outside their authority to pass upon. They also noted that no malice or bad faith was proven in the case.
  • The Supreme Court agreed with the OCA's findings and imposed a fine of P10,000 on Judge Pedronio for the undue delay in rendering a decision and gross ignorance of the law.
  • Since Judge Pedronio died during the pendency of the complaint, the Supreme Court considered the case closed and terminated. The decision was ordered to be furnished to relevant offices and organizations.

Issue:

  • (Unlock)

Ruling:

  • Yes, Judge Pedronio committed grave abuse of discretion, gross incompetence, and inefficiency amounting to ignorance o...(Unlock)

Ratio:

  • The Office of the Court Administrator (OCA) found that Judge Pedronio misapplied the Mabunay ruling, resulting in the delay of the promulgation of People v. Baylon. However, the OCA also noted that the delay prior to February 7, 2002, was due to repeated rescheduling of the promulgation, which was not entirely within Judge Pedronio's control. The OCA recommended a reprimand for t...continue reading

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