A.M. No. RTJ-16-2455 - Castro vs. Mangrobang

Case Summary (A.M. No. RTJ-16-2455)

Factual Background in Civil Case No. 2187-00

On October 5, 2000, Castro filed Civil Case No. 2187-00 before the RTC of Imus, Cavite, against spouses Jamir and Rosalyn Guevarra (spouses Guevarra). Castro sought the cancellation of an undated FEBTC check, FEBTC Check No. 0133501, worth P1,862,000.00, asserting that the corresponding obligation had already been fully paid. She also prayed that two other FEBTC checks—FEBTC Check Nos. 0133574 and 0133575—dated March 24, 2000 and March 31, 2000, and each worth P10,000.00, be declared without value; that the spouses Guevarra be ordered to return P477,257.00 as excess payments, with interest; and that she be awarded exemplary damages, moral damages, and attorney’s fees.

The spouses Guevarra denied Castro’s theory and claimed that the checks were issued by Castro in exchange for rediscounted checks in Rosalyn Guevarra’s possession. They also alleged that Castro had only paid P230,000.00 of the alleged obligation.

After Castro issued a stop payment order on the three checks, spouses Guevarra filed criminal complaints under the Bouncing Checks Law with the Municipal Trial Court (MTC) of Imus, Cavite. During the civil trial before Judge Espanol, spouses Guevarra moved for subpoena ad testificandum and subpoena duces tecum for certain bank officials and documents, but Judge Espanol denied those motions.

Spouses Guevarra then challenged the denial through a Petition for Certiorari before the Court of Appeals, docketed as CA-G.R. SP No. 80561. While that petition was pending, they did not file a Formal Offer of Evidence before RTC-Branch 90 and instead filed a Motion to Defer Action on December 15, 2003.

Decision of Judge Espanol and Subsequent Motions

Judge Espanol rendered a Decision on December 22, 2003 granting Castro’s claims and ordering, among others: cancellation of FEBTC Check No. 0070789 and replacement FEBTC Check No. 0133501, both in the amount of P1,862,000.00; declaration without value of FEBTC Check Nos. 0133574 and 0133575; return of P477,257.00 with legal interest at 12% per annum; moral damages, exemplary damages, attorney’s fees, and costs; and dismissal of an estafa criminal case for lack of factual and legal basis. The Decision also directed the Clerk of Court to furnish the MTC regarding the status of the criminal cases involving the checks.

In the body of the Decision, Judge Espanol stated that the denial of the Motion to Defer Action was pursuant to Section 7, Rule 65 of the 1997 Rules of Civil Procedure.

Spouses Guevarra filed on January 26, 2004 a Motion for Reconsideration, alleging, among others, that the Decision was promulgated after Judge Espanol’s retirement, contrary to law and facts, and issued without due process because they were allegedly denied the right to present evidence. On January 28, 2004, they filed a Motion to Re-Raffle Case due to the retirement of Judge Espanol on January 9, 2004 and the uncertainty of the replacement judge’s appointment.

The Executive Judge issued an Order on January 28, 2004 granting the Motion to Re-Raffle Case. Civil Case No. 2187-00 was consequently raffled to RTC-Branch 22, presided by Judge Mangrobang.

Judge Mangrobang’s Omnibus Order and the Course of Proceedings

On December 15, 2004, Judge Mangrobang issued an Omnibus Order resolving the Motion to Defer Action and the Motion for Reconsideration. He found merit in the claim that the Decision dated December 22, 2003 was null and void because it was allegedly promulgated after Judge Espanol’s retirement. Judge Mangrobang emphasized that the failure of Judge Espanol to file the Decision with the Clerk of Court was “very vital and cannot just be considered as one simple procedural lapse.” He relied on established doctrine that rendition of judgment occurs upon filing with the Clerk of Court, not merely upon writing, signing, or pronouncement in open court. He also found no justifiable excuse for the failure to serve the Decision during the incumbency or before retirement.

Judge Mangrobang consequently set aside Judge Espanol’s Decision dated December 22, 2003, and he ordered that proceedings be held in abeyance until after the Court of Appeals ruled on the pending petition in CA-G.R. SP No. 80561, considering the then-pending certiorari.

The Court of Appeals dismissed the spouses Guevarra’s Petition for Certiorari in CA-G.R. SP No. 80561 through a Decision dated July 20, 2006, stating that the issues had become moot in light of the Decision dated December 22, 2003 rendered by RTC-Branch 90.

On October 20, 2006, spouses Guevarra moved before RTC-Branch 22 to revive proceedings and/or for a new trial so they could complete evidence presentation by submitting newly discovered evidence. Judge Mangrobang granted the Motion on March 23, 2007, setting new trial for April 27, 2007 at 8:30 a.m.

Castro’s Challenge Before the Court of Appeals and the Supreme Court

Castro filed on July 19, 2007 before the Court of Appeals a Petition for Certiorari, Prohibition and Mandamus with prayer for a TRO, docketed as CA-G.R. SP No. 99763, challenging Judge Mangrobang’s Order dated March 23, 2007 and collaterally attacking his Omnibus Order dated December 15, 2004 for alleged grave abuse of discretion. The Court of Appeals denied the petition in a Decision dated April 26, 2010, ruling that the petition should have been dismissed outright for Castro’s failure to file a Motion for reconsideration of the March 23, 2007 Order, and that the Order was issued within the trial court’s authority and discretion.

Castro’s Motion for Reconsideration was denied in a Resolution dated June 29, 2010. She then filed a Petition for Review on Certiorari with the Supreme Court, docketed as G.R. No. 192737. On April 25, 2012, the Supreme Court denied Castro’s petition.

The Supreme Court sustained Judge Mangrobang’s Omnibus Order dated December 15, 2004, reasoning that (1) the case was properly assigned to RTC-Branch 22 and Judge Mangrobang had authority to dispose of pending incidents, including the Motion for Reconsideration; and (2) the Omnibus Order had become final because Castro failed to avail herself of available remedies to question it. The Supreme Court nevertheless held that the Court of Appeals should have given due course to Castro’s certiorari as an exception, since there was allegedly no legal basis for the March 23, 2007 Order granting new trial. It explained that a motion for new trial is available only against a judgment not yet final, and that spouses Guevarra’s motion was premature because RTC-Branch 22 had not yet rendered a decision. In the interest of justice, however, the Supreme Court allowed spouses Guevarra to adduce evidence before RTC-Branch 22 and to thereafter make their formal offer, leaving the trial court to decide the case on the merits if Castro did not present rebuttal evidence.

Subsequent Motions in Civil Case and Castro’s Administrative Complaint

During the pendency of the certiorari proceedings in the Court of Appeals and later the Supreme Court, Castro filed on July 20, 2007 a Motion to Suspend Proceedings in Civil Case No. 2187-00, citing her petition filed in CA-G.R. SP No. 99763. Judge Mangrobang denied the Motion on November 3, 2008, noting that the Court of Appeals had not issued any TRO or writ of preliminary injunction, even after more than a year.

After Castro’s third lawyer withdrew, she sought counsel assistance. During a hearing on April 16, 2009, Castro herself requested postponement or suspension to find another lawyer and to allow the appellate court time to resolve CA-G.R. SP No. 99763. Judge Mangrobang granted her time until May 28, 2009 to secure new counsel but denied suspension while her petition remained pending.

On April 23, 2009, Castro filed a Motion for Inhibition charging Judge Mangrobang with manifest bias and partiality in favor of spouses Guevarra, allegedly in violation of her right to due process. Judge Mangrobang denied that Motion in an Order dated July 30, 2009. At the end of the Order, Judge Mangrobang denied the Motion for Inhibition, set the hearing, sternly warned Castro to appear with counsel, and stated that otherwise she would be deemed to have waived her right to present evidence and that the court would allow defendants to start presentation.

Castro filed, through new counsel, on August 26, 2009, an Omnibus Motion with leave of court, seeking reconsideration among other reliefs. On September 18, 2009, she filed a Manifestation and Motion to Admit a Postmaster’s Certification to prove that her reply to the Opposition (to the Motion for Inhibition) was delivered. She later filed an Urgent Motion for Postponement, citing lack of counsel and Judge Mangrobang’s failure to rule on her pending Omnibus Motion and Motion to Admit Postmaster’s Certification.

On June 15, 2010, Castro filed the administrative complaint-affidavit with the OCA. She asserted that Judge Mangrobang failed to promptly resolve pending motions in Civil Case No. 2187-00 and stressed that a judge must act on pending matters within the constitutional 90-day reglementary period. She also challenged the Omnibus Order dated December 15, 2004, arguing it violated Section 7, Rule 65 of the Revised Rules of Court by allegedly holding the principal case in abeyance despite no TRO or preliminary injunction. She further alleged that Judge Mangrobang showed bias by deferring action for spouses Guevarra due to their pending certiorari petition and later denying her Motion to Suspend Proceedings using the same rationale.

Castro maintained that Judge Mangrobang acted maliciously and in bad faith in issuing various Orders, including those dated December 15, 2004, March 23, 2007, November 3, 2008, April 16, 2009, and July 30, 2009. She contended that Judge Espanol had in fact already denied the Motion to Defer Action and that Judge Mangrobang’s contrary treatment was deliberate, permitting spouses Guevarra to benefit from a TRO that the Court of Appeals had already denied.

Case Syllabus (A.M. No. RTJ-16-2455)

Parties and Procedural Posture

Nemia Castro filed an administrative complaint before the Office of the Court Administrator (OCA) against Judge Cesar A. Mangrobang, Regional Trial Court, Branch 22, Imus, Cavite.
The administrative complaint alleged Gross Inefficiency, Neglect of Duty, Gross Ignorance of the Law, and Manifest Bias and Partiality.
The complaint arose from Civil Case No. 2187-00, entitled Nemia Castro v. Rosalyn Guevarra, sued with her husband, Jamir Guevarra.
The Court later acted on the OCA Report and the parties’ manifestations submitted after the Court required them to confirm submission for decision.
The Court found Judge Mangrobang guilty of undue delay in resolving pending matters, and fined him accordingly.
The Court dismissed the charges relating to denial of inhibition and held that the administrative case was improper to assail certain judicial acts.

Key Factual Allegations

Civil Case No. 2187-00 was an action for Cancellation and/or Discharge of Check and Defamation/Slander with Damages, filed on October 5, 2000 before the RTC of Imus, Cavite.
The case was originally raffled to RTC-Branch 90, presided by Judge Dolores Espanol, where Castro sought cancellation of an undated FEBTC Check No. 0133501 in the amount of P1,862,000.00, and other reliefs including declaration without value of FEBTC Check Nos. 0133574 and 0133575 and recovery of P477,257.00 plus damages and attorney’s fees.
Spouses Guevarra countered that the questioned checks were issued in exchange for rediscounted checks and that only P230,000.00 of Castro’s obligation had been paid.
Spouses Guevarra also filed criminal complaints under the Bouncing Checks Law after Castro issued a stop payment order.
During trial, spouses Guevarra moved for subpoena ad testificandum and subpoena duces tecum for certain bank officials and documents, but Judge Espanol denied those motions.
After the denial of the motions, spouses Guevarra challenged Judge Espanol’s rulings through a Petition for Certiorari before the Court of Appeals, docketed as CA-G.R. SP No. 80561.
Because of the pending certiorari petition, spouses Guevarra did not file a Formal Offer of Evidence before RTC-Branch 90 and instead filed a Motion to Defer Action on December 15, 2003.
Judge Espanol rendered a decision on December 22, 2003, which, among others, granted Castro’s claims and dismissed a related criminal case for estafa.
After Judge Espanol’s retirement, spouses Guevarra moved for reconsideration and re-raffling, and the case was transferred to RTC-Branch 22 presided by Judge Mangrobang.
Judge Mangrobang issued an Omnibus Order on December 15, 2004, granting spouses Guevarra’s motion for reconsideration, setting aside the December 22, 2003 decision as null and void, and ordering the proceedings to be held in abeyance pending the appellate ruling in CA-G.R. SP No. 80561.
The Court of Appeals dismissed spouses Guevarra’s petition in CA-G.R. SP No. 80561 on July 20, 2006.
Spouses Guevarra then sought revival and new trial through a motion, which Judge Mangrobang granted by ordering a new trial set on April 27, 2007.
Castro challenged Judge Mangrobang’s orders through a certiorari petition in CA-G.R. SP No. 99763, questioning the March 23, 2007 order granting new trial and collaterally attacking the December 15, 2004 Omnibus Order.
The Court of Appeals denied Castro’s petition on April 26, 2010, and Castro’s later review in G.R. No. 192737 also resulted in denial on April 25, 2012, with the Supreme Court sustaining the December 15, 2004 Omnibus Order and treating the March 23, 2007 grant of new trial as premature.
Castro later sought to suspend proceedings due to her petition, moved for inhibition alleging bias and partiality, and later filed motions to reconsider adverse rulings.
Castro’s administrative complaint specifically faulted Judge Mangrobang’s denial of inhibition and claimed undue delay in the disposition of pending motions.

Administrative Complaint Charges

Castro alleged that Judge Mangrobang committed Gross Inefficiency by failing to act promptly on pending motions in Civil Case No. 2187-00 within the ninety-day period mandated by constitutional and doctrinal standards.
Castro argued that a judge must dispose of motions and interlocutory matters within the reglementary period unless a shorter period is required by law.
Castro contended that Judge Mangrobang’s Omnibus Order dated December 15, 2004 violated Section 7, Rule 65 of the Revised Rules of Court because the petition allegedly did not interrupt the principal case without a temporary restraining order or writ of preliminary injunction.
Castro claimed that Judge Mangrobang showed bias and partiality by granting spouses Guevarra’s Motion to Defer Action on account of their pending petition, and by later denying Castro’s Motion to Suspend Proceedings on the ground that the petition before the appellate court had not resulted in a TRO or preliminary injunction.
Castro invoked Rule 1.02 of the Code of Judicial Conduct on impartial administration of justice and freedom from impropriety.
Castro further alleged that Judge Mangrobang acted maliciously, deliberately, and in bad faith in issuing multiple orders, including those dated December 15, 2004, March 23, 2007, November 3, 2008, April 16, 2009, and July 30, 2009.
Castro denied that Judge Espanol had not ruled on the Motion to Defer Action by stressing that Judge Espanol had already denied it in the December 22, 2003 decision.
Judge Mangrobang, in his Comment, characterized Castro as a “disgruntled litigant” and argued that administrative liability requires more than error absent fraud, dishonesty, or deliberate intent.

Issues Raised

The Court framed the core administrative issues around whether Judge Mangrobang committed reversible misconduct in: (a) denying Castro’s Motion for Inhibition, and (b) unduly delaying resolution of certain pending matters.
The Court examined whether the denial of inhibition was supported by the standards