A.M. No. MTJ-94-902 - Asinas Jr. vs. Judge Ernesto Trinidad

Case Summary (A.M. No. MTJ-94-902)

Initiation of the Administrative Complaint

Asinas alleged that Judge Trinidad committed (1) inefficiency and neglect in the performance of duties, and (2) knowingly rendering an unjust and unfounded judgment in the above criminal cases. Asinas’ principal grievance on inefficiency was timeliness. Although the cases were tried under the Rules on Summary Procedure, the judge allegedly disposed of them after an extended period. Asinas claimed that delays persisted despite repeated follow-ups. He further stated that the acquittal was rendered on July 22, 1993, which he characterized as about one year and seven months from submission for decision on October 19, 1991, and he later emphasized the overall time consumed from trial submission.

As to the second charge, Asinas assailed a portion of the acquittal decision where the trial court allegedly expressed doubt that Asinas’s testimony—on the destruction of his camera by Paglinawan—could be believed because there was “no witness” to corroborate it. Asinas contended that his testimony was corroborated in all respects by a prosecution witness, Rene Villanueva, whose affidavit dated October 20, 1987 was presented in court and who testified and was cross-examined by the defense.

Respondent Judge’s Comment and Explanation of Delay

In his Comment, Judge Trinidad attributed the overall delays to the parties and the procedural history of related disputes. He stated that after the criminal cases were filed on December 24, 1987, he directed the accused to file counter-affidavits. He then narrated that on January 27, 1988, the accused moved to suspend the proceedings and refer the case to the Department of Labor. When the motion was denied, the accused filed a petition for certiorari with the Supreme Court, which was eventually referred to the Court of Appeals.

According to Judge Trinidad, the criminal cases were suspended because of the pendency of the petition and also because the parties were settling a labor controversy with the Department of Labor. After waiting for two years for the labor dispute’s outcome, Judge Trinidad resumed the proceedings on February 7, 1990 and continued until the trial ended on December 4, 1991.

Judge Trinidad also claimed that after the parties rested, Asinas requested deferral of resolution. The request was allegedly grounded on the continuation of negotiations related to the labor dispute and the belief that a decision in the criminal cases might impede settlement. Judge Trinidad further stated that in July 1993, Asinas and the private prosecutor again approached him and informed the court that the labor dispute had finally been settled and that both Asinas and the accused, identified as officers and members respectively of Nestle Philippines, Inc., had mutually agreed to withdraw cases filed against each other. At that stage, Judge Trinidad asserted that he still promulgated the decision on August 2, 1993, despite the parties’ apparent intention to withdraw, because both sides had already rested.

On the allegation that he had doubted the credibility of Asinas’s testimony, Judge Trinidad maintained that he did not intend to imply that Asinas lied about the camera’s destruction. He explained that the accused were acquitted due to the prosecution’s failure to prove guilt beyond reasonable doubt, not because of a finding of dishonesty.

Supreme Court’s Referrals for Investigation and Reports

In a resolution dated February 23, 1994, the Supreme Court referred the matter to Executive Judge Salvador S. Abad Santos of the Regional Trial Court of Makati for investigation, report, and recommendation.

In a Report dated April 22, 1994, the Investigating Judge found unjustifiable delay in the resolution of Criminal Cases Nos. 130338 and 130339. Judge Santos observed that even if earlier delays could be attributed to the parties, the trial ended on December 4, 1991, yet judgment was not promulgated until August 2, 1993. The Investigating Judge therefore concluded that Judge Trinidad remained culpable for the late promulgation.

Regarding the “unjust and unfounded judgment” charge, the Investigating Judge treated it as unsubstantiated. The Investigating Judge emphasized that the complaint did not show that the assailed judgment resulted from failure to consider facts or misappreciation amounting to an administrative wrong. Rather, the issue raised called for assessment of witness credibility, which is the trial judge’s domain.

The Investigating Judge recommended that Judge Trinidad be reprimanded for unjustifiable delay, while acknowledging that his culpability could be mitigated because judgment had been rendered, albeit belatedly.

Office of the Court Administrator Evaluation

By a resolution dated May 23, 1994, the Supreme Court referred the case to the Office of the Court Administrator for evaluation, report, and recommendation. In a Memorandum dated July 8, 1994, Deputy Court Administrator Juanito A. Bernad highlighted that both criminal cases fell under the Rules on Summary Procedure, specifically referencing Section 1, B(4), Revised Rule on Summary Procedure.

The memorandum specified the charges and punishments that brought each case within summary jurisdiction. In Criminal Case No. 130338, the accused faced unjust vexation punishable by arresto menor or a fine ranging from P5.00 to P200.00, or both, under Article 287 of the Revised Penal Code. In Criminal Case No. 130339, the accused were charged with malicious mischief involving the destruction of a Kodak instamatic camera valued at P649.95, punishable by arresto mayor in its minimum and medium periods if the value of damage exceeded P200.00 but did not exceed P1,000.00, under Article 329 of the Revised Penal Code.

The Office of the Court Administrator then stressed that, notwithstanding summary procedure, the proceedings had consumed almost four years to terminate. It distinguished between types of delay. It opined that delays in the proceedings might not be attributable to the respondent judge and were mainly linked to petitions filed before higher tribunals and to the labor proceedings. However, it treated the delay in resolution and promulgation of judgment as a separate matter.

Citing Section 17 of the Rule on Summary Procedure, the memorandum stated that where a trial had been conducted, the court was required to promulgate judgment not later than thirty (30) days after the termination of trial. It computed that, since the trial ended on December 4, 1991, promulgation should have occurred no later than January 3, 1992, yet the decision was promulgated on August 2, 1993. The Office thus characterized the delay as one (1) year and seven (7) months, holding it attributable to Judge Trinidad.

The memorandum further invoked the principle that failure to decide within the required period is not excusable and amounts to gross inefficiency, citing Longboan vs. Polig, 186 SCRA 557 (1990), which in turn cited Ubarra vs. Tecson, 134 SCRA 4 (1985), De Leon vs. Castro, 104 SCRA 241 (1981), and In re: Judge Jose F. Madara, 104 SCRA 245 (1981).

On the “unjust and unfounded judgment” charge, the Office concurred with the Investigating Judge. It held that the complaint failed to demonstrate that the decision was unreasonable, capricious, or reflective of bad faith or malice. It also noted that the challenged portion involved credibility assessment and appreciation of evidence by the trial judge, not an administrative wrong.

Complainant’s Reply and Claimed Irrelevance of Labor Dispute

In reply, Asinas denied Judge Trinidad’s claim that he had requested deferment. He asserted that as early as December 19, 1990, the Supreme Court, in G.R. Nos. 88710-13, had ruled that the accused had already lost employee status for having engaged in an illegal strike, and that outcomes i

Case Syllabus (A.M. No. MTJ-94-902)

The complainant, Emeterio L. Asinas, Jr., filed a sworn letter-complaint against Judge Ernesto T. Trinidad, then presiding over the Metropolitan Trial Court, Branch 63, Makati.
The complaint charged the respondent judge with (one) inefficiency and neglect in the performance of duties and (two) knowingly rendering an unjust and unfounded judgment in Criminal Cases Nos. 130338 and 130339.
The administrative case proceeded through referral for investigation and recommendation, evaluation by the Office of the Court Administrator, and final resolution by the Court.
The Court ultimately found the respondent judge administratively liable for unjustifiable delay and dismissed the other charge for lack of merit.

Parties and Procedural Posture

The complainant acted as the complaining witness in the underlying criminal cases and as the initiating party in the administrative complaint.
The respondent judge was charged in his official capacity as the trial judge who handled the criminal cases.
The Court referred the matter to an Executive Judge for investigation, report, and recommendation.
The investigating judge found unjustifiable delay and recommended reprimand, with mitigation because judgment had been rendered albeit late.
The Court later referred the case to the Office of the Court Administrator for evaluation, report, and recommendation.
The Deputy Court Administrator emphasized that the underlying cases were governed by the Rules on Summary Procedure, especially the timeline for promulgating judgment.

Key Factual Allegations

The complainant alleged that the criminal cases were tried under the Rules on Summary Procedure yet remained unresolved for an excessive period.
The complainant asserted that while the cases were submitted for decision on October 19, 1991, the judgment of acquittal was rendered only on July 22, 1993.
The complainant also pointed out that after follow-ups, the assailed judgment was not promptly promulgated.
The complainant further assailed a portion of the decision that declared doubt on his testimony about the destruction of his camera.
The complainant claimed that his testimony regarding the destruction of the camera was corroborated by prosecution witness Rene Villanueva, whose affidavit dated October 20, 1987 was presented in court and who testified subject to cross-examination.

Underlying Criminal Cases

The first criminal case, Criminal Case No. 130338, involved a charge of unjust vexation punishable with arresto menor or a fine of P5.00 to P200.00, or both.
The charge under Criminal Case No. 130338 was anchored on the second paragraph of Article 287 of the Revised Penal Code.
The second criminal case, Criminal Case No. 130339, involved a charge of malicious mischief relating to destruction of a Kodak instamatic camera.
The complainant’s allegations in Criminal Case No. 130339 placed the damage at P649.95, with punishment under Article 329 of the Revised Penal Code depending on the damage bracket.
The Office of the Court Administrator and the Court recognized that both cases fell within the coverage of the Rules on Summary Procedure, notwithstanding their separate legal characterizations.

Respondent Judge’s Explanations

The respondent judge contended that much of the delay was attributable to the parties.
He stated that after the cases were filed on December 24, 1987, he directed the accused to file counter-affidavits in an order dated January 5, 1988.
The respondent judge narrated that on January 27, 1988, the accused filed a motion to suspend proceedings and refer the case to the Department of Labor.
He explained that denial of the motion led the accused to file a petition for certiorari with the Supreme Court, later referred to the Court of Appeals.
The respondent judge asserted that because of the pendency of the petition with the Court of Appeals and ongoing labor dispute negotiations, he suspended the criminal proceedings.
He claimed that after waiting for the labor dispute for about two years, he resumed the cases and commenced hearings from February 7, 1990 up to December 4, 1991.
He further alleged that after the parties rested, the complainant requested deferment of resolution due to continuing negotiations.
The respondent judge asserted that the parties later informed him in July 1993 that the labor dispute was settled and that both sides mutually agreed to withdraw the cases they had filed against each other.
Despite these developments, the respondent judge promulgated the decision on August 2, 1993.
For the credibility-related criticism in the decision, the respondent judge maintained that the statement about doubt did not aim to imply that the complainant lied.
He explained that the accused were acquitted for failure of the prosecution to prove guilt beyond reasonable doubt.

Complainant’s Reply Arguments

The complainant denied that he had requested deferment of the resolution after the parties had rested.
The complainant argued that by December 19, 1990, the Supreme Court had already ruled in G.R. Nos. 88710-13 that the accused had lost employee status due to an illegal strike.
The complainant maintained that the outcome of the criminal cases would therefore not bear on the labor