Case Summary (A.M. No. MTJ-16-1880)
Allegations and Complaints
In her verified Complaint-Affidavit submitted on January 17, 2013, Elgar claimed that her husband left two parcels of agricultural land through a Deed of Donation Mortis Causa on August 18, 1999. She filed a petition on January 7, 2010, for the allowance of this deed. The initial hearing had significant developments, primarily influenced by the actions and encouragements of Judge Santos for the involved parties to reach an amicable settlement. Elgar alleged that due to Judge Santos’s persistent pressure to settle, there was a hindrance to the proper proceedings of the case.
Overview of Respondent's Actions
Judge Santos actively sought an amicable resolution, sending numerous messages to Elgar's counsel advocating for settlement and initiating frequent discussions regarding possible settlements within and outside the court. On several occasions, he proposed specific terms and urged the parties to bring any necessary co-heirs, causing Elgar to feel that his actions were beyond his authority and jurisdiction, particularly given the ex parte communications he had facilitated and his overbearing insistence on settlement.
Findings of the Office of the Court Administrator (OCA)
The Office of the Court Administrator submitted a report on September 17, 2015, determining that while some of Judge Santos's actions were not administratively liable, he was nevertheless guilty of attempting to enforce an amicable settlement in a manner that impaired the expediency of the case resolution. The OCA found fault with his undue delays in the proceedings, which extended from January 7, 2010, when the petition was filed, until its withdrawal on December 11, 2012, without progressing beyond pre-trial.
Judicial Conduct Violations Found
Ultimately, the OCA concluded that Judge Santos had violated several canons of the New Code of Judicial Conduct. Although he was not held liable for failing to limit his inquiry to the deed's validity or for requiring information on properties that were outside the petition's scope, he was held culpable for his insistence on producing an amicable settlement and for issuing an Extended Order directed towards Elgar’s counsel after the petition had been withdrawn, which was deemed uncalled for.
Court's Ruling and Sanctions
The court partly adopted the findings of the OCA, affirming Santos's lack of administrative liability for some actions, while determining he was guilty of other misconduct. A significant sanction was imposed—a cumulative fine amounting to P
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Background of the Case
- This administrative matter originated from a Complaint-Affidavit filed by Susan R. Elgar against Judge Soliman M. Santos, Jr., who served as the Presiding Judge of the Municipal Circuit Trial Court (MCTC), Nabua-Bato, Camarines Sur.
- The complaint alleged gross ignorance of the law and violations of the Code of Judicial Conduct and Canons of Judicial Ethics concerning Special Proceedings No. 1870, which involved a petition for the allowance of a Deed of Donation Mortis Causa by the deceased Wenceslao Elgar.
Complainant's Version
- Susan R. Elgar claimed that her late husband executed a Deed of Donation Mortis Causa on August 18, 1999, donating two parcels of agricultural land to her.
- She filed a petition for allowance of this deed on January 7, 2010, which was initially declared sufficient by Acting Presiding Judge Bernhard B. Beltran.
- Subsequent to Judge Beltran, Judge Santos took over and exhibited a strong inclination towards amicable settlement, as evidenced by various communications and postings advocating for such resolutions.
- Judge Santos frequently contacted Elgar’s counsel via text messages urging settlement discussions and proposed meetings on the day of hearings.
- Elgar felt pressured by Judge Santos to settle the case, leading to a significant delay in the proceedings which extended for almost two years without reaching a resolution.
Respondent's Version
- Judge Santos defended his actions by asserting that