Case Summary (G.R. No. L-38975)
Allegations of Delay
Candido Bulan filed a complaint against Judge Cardenas alleging that the trial of Criminal Case No. 78, initiated on September 26, 1962, was significantly delayed. Bulan asserted that the trial had been postponed for nearly ten years despite repeated requests for settings by both him and the accused. In an affidavit dated January 30, 1973, Judge Cardenas explained that he had been pressured to grant these postponements due to appeals made by Bulan and the then Mayor of Tuao, Francisco Mamba, asserting that the Mayor's influence made it difficult to resist such requests.
Investigation Findings
The case was investigated, leading to a report from Judge Jesus B. Ruiz, which indicated that Judge Cardenas had repeatedly scheduled hearings, but they were postponed primarily at the request of Bulan or the accused. Ruiz’s findings pointed out that both Bulan and the special counsel failed to actively seek hearings, although the judge had the authority to dismiss the case for lack of prosecution. Additionally, it was noted that Bulan was also facing charges in a separate case for Multiple Murder, contributing further to the case's delay.
Legal Standards and Violations
Justice Manuel Barcelona’s memorandum noted that Judge Cardenas had contravened Section 3 of Rule 22 of the Revised Rules of Court regarding adjournments and postponements, by allowing prolonged delays without proper justification or written authorization. The rule mandates that court adjournments cannot exceed specified time limits unless sanctioned by the Chief Justice, and any breach of this rule could signify negligence or misconduct in the judge's duties.
Conclusion of Proceedings
The en banc Court subsequently convened on July 1, 1975, to hear the case; however, neither party appeared in court. Following this absence, the case was submitted for decision, leading to the conclusion that the long-standing delays constituted a willful disregard for judicial obligations and a breach of duty by the respondent judge. Furthermore, the Court emphasized that delays in criminal proceedings are det
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Case Background
- Candido Bulan filed a complaint against Teofilo B. Cardenas, a Municipal Judge in Tuao, Cagayan, for undue delay in the trial of a criminal case for Serious Physical Injuries (Crim. Case No. 78) against Nemesio Palmea.
- The case was filed on September 26, 1962, but had been pending for nearly ten years due to multiple postponements and requests for delays.
- The original judge inhibited himself due to a familial relationship with the accused, leading to Judge Cardenas being assigned to the case.
Allegations Against the Respondent Judge
- Bulan alleged that despite repeated requests for trial, Judge Cardenas failed to set the case for hearing over a period of ten years.
- Cardenas explained that hearings were postponed at the request of both Bulan and the accused, citing reasons such as the absence of legal counsel.
- Mayor Francisco Mamba of Tuao, Cagayan, reportedly pressured Judge Cardenas to postpone hearings, claiming Bulan was essential for operations at Mamba's gasoline station.
Investigation and Findings
- The case was referred for investigation to Judge Jesus B. Ruiz, who reported that Cardenas was not solely at fault for the delays.
- Ruiz noted that:
- Hearings were set f