Title
Bunyi vs. Caraos
Case
A.M. No. MTJ-00-1307
Decision Date
Sep 6, 2000
A judge's delay in resolving criminal cases and perceived partiality in a dispute over market vendors' relocation led to a Supreme Court reprimand for inefficiency and a warning against bias.
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Case Summary (A.M. No. MTJ-00-1307)

Background of the Case

  • Complainants are members of the Sangguniang Bayan of Candelaria, Quezon.
  • In 1996, the Sangguniang Bayan decided to demolish the old public market building for a new construction.
  • A temporary market site was designated for market vendors, and an ordinance was passed prohibiting vendors from operating in the PNR compound.
  • Over 300 market vendors began operating in the PNR compound without a Mayor's permit, leading to criminal cases filed against them in the Municipal Trial Court of Candelaria, Quezon.

Delays in Judicial Proceedings

  • The arraignment of the accused was scheduled for December 10, 1996, with the trial set for January 28, 1997.
  • The respondent judge failed to appear on the trial date without providing an explanation.
  • As of February 17, 1997, the cases remained pending, prompting the filing of an administrative complaint against the judge.

Judicial Conduct and Efficiency

  • The Court emphasized the importance of Rule 3.05 of Canon 3 of the Code of Judicial Conduct, which mandates judges to dispose of court business promptly.
  • Delays in judicial proceedings undermine public confidence in the judiciary and tarnish its image.
  • The Office of the Court Administrator (OCA) found that the one-year delay in the status of the cases constituted inefficiency and a violation of judicial conduct.

Impartiality of the Judge

  • The Court noted that the respondent judge's comments regarding the relocation of vendors, although seemingly innocent, should have been avoided to prevent any appearance of bias.
  • Judges must not only be impartial but also appear impartial to maintain public trust in the judicial system.

Respondent's Defense

  • The respondent judge characterized the complaint as harassment and attributed delays to political conflicts and the actions of the complainants' lawyers.
  • He claimed that the postponements and arguments among counsel contributed to the delays in the cases.

Findings of the Office of the Court Administrator

  • The OCA determined that...continue reading

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