A.M. No. RTJ-21-014 - Dr. Julian L. Espiritu, Jr., represented by Rubenito R. Del Castillo, vs. Presiding Judge Santiago M. Arenas, Regional Trial Court of Quezon City

Case Summary (A.M. No. RTJ-21-014)

Key Dates and Procedural Posture

Trial court decision in favor of complainant promulgated July 13, 2010; appellate affirmances and entries of judgment occurred (CA and Court decisions reflected in records with entries of judgment dated November 25, 2014 and February 3, 2015). Motion for execution filed by complainant in 2015; contested events and subsequent pleadings continued through 2017; the specific incident found to have been decided late was resolved by Judge Arenas’ Order dated July 6, 2018. Judge Arenas compulsorily retired from the Judiciary on October 27, 2020. Supreme Court resolution promulgated by the En Banc on December 5, 2023. Applicable constitutional framework is the 1987 Constitution (Art. VIII, Sec. 15(1)).

Applicable Law and Rules

The Court applied the 1987 Constitution (Article VIII, Section 15(1) — prescribed periods for resolution of cases and matters), and Rule 140 of the Rules of Court as further amended (including retroactivity under Section 24 and disciplinary provisions on neglect of duty and fines under Sections 14(d), 15(6), 17(2), 19(2)(a), 20, and 22). The Court also relied on settled jurisprudence distinguishing judicial acts (reviewable by judicial remedies) from administrative offenses, and on definitions of simple versus gross neglect of duty from prior cases.

Allegations by Complainant

Complainant alleged that: (1) Judge Arenas unduly delayed the resolution of a Motion for Execution filed in July 2015, resolving it almost three years later by an Order dated July 6, 2018; and (2) despite finality of the decision in the main case, Judge Arenas entertained subsequent pleadings by defendants and allowed testimony during execution proceedings—acts said to amount to reopening a final decision and constituting gross ignorance of the law and gross inefficiency.

Respondent’s Explanation and Defense

Judge Arenas contended that: (1) the motion for execution was resolved by an Order dated August 31, 2016 and the writ of execution issued on August 18, 2017, undermining the allegation of a three‑year delay on that motion; (2) any perceived delay or activity in the execution proceedings was attributable to subsequent pleadings, motions, and resets initiated by the parties, not to his inaction; (3) he repeatedly cautioned parties against prolonging execution and recognized the ministerial duty to issue writs after finality, but also noted exceptions and the necessity to consider pending motions connected to execution; and (4) he urged dismissal of the administrative complaint.

OCA Findings and Recommendation

The Office of the Court Administrator (OCA) recommended: (a) dismissal of the gross ignorance of the law charge as judicial in nature (acts were within judicial discretion and subject to judicial remedies); and (b) administrative liability for undue delay limited to the Motion to Enjoin Implementation of the Writ of Execution filed November 9, 2017 — because the last pleading (Rejoinder) was filed December 7, 2017, and the matter was only resolved by Order dated July 6, 2018 (a seven‑month lapse). The OCA recommended a fine of PHP 15,000.00, to be deducted from retirement benefits.

Issue Presented to the Court

Whether Judge Arenas should be held administratively liable for the acts complained of — specifically whether his conduct amounted to gross ignorance of the law or to undue delay/neglect of duty justifying disciplinary sanction under the Rules and the Constitution.

Court’s Jurisdiction and Rules Applied

The Court confirmed that the amended Rule 140 (effective after its 2022 amendments) applies to pending administrative cases (Section 24) and that the respondent’s compulsory retirement does not divest the Court of jurisdiction once disciplinary proceedings were instituted (Rule 140, Section 2(2) and applicable case law). Accordingly, the Court proceeded to decide the administrative charges under the amended Rules.

Judicial Acts Versus Administrative Offense: Gross Ignorance Dismissed

The Court adopted the OCA’s view that entertaining subsequent pleadings during execution and allowing testimony were judicial acts falling within judicial discretion. Such acts are reviewable by judicial remedies (e.g., appeal or certiorari) and thus do not, per se, constitute an administrative offense of gross ignorance of the law. The gross ignorance charge was therefore dismissed for being essentially judicial in nature.

Undue Delay Analysis and Deeming of Submission for Resolution

Under Article VIII, Section 15(1) of the 1987 Constitution, lower court judges must resolve cases or matters within three months from the date of submission for resolution, and a matter is deemed submitted upon filing of the last pleading. The Court agreed with the OCA that the Motion to Enjoin Implementation of the Writ of Execution was submitted for resolution on December 7, 2017 (date of the last pleading), but was only resolved by Order on July 6, 2018 — a seven‑month interval. Absent justifiable reasons, this constituted undue delay.

Nature of Neglect: Simple versus Gross Neglect of Duty

Drawing on established jurisprudential definitions, the Court distinguished simple neglect (failure to give proper attention through carelessness or indifference) from gross neglect (conscious indifference or flagrant breach). Given the circumstances and ab

Case Syllabus (A.M. No. RTJ-21-014)

Nature of the Case and Procedural Posture

Administrative disciplinary proceeding filed under A.M. No. RTJ-21-014, decided En Banc on December 05, 2023.
Complaint filed by Dr. Julian L. Espiritu, Jr., represented by Rubenito R. Del Castillo, against Presiding Judge Santiago M. Arenas of RTC Quezon City, Branch 217.
Complaint alleges Gross Ignorance of the Law and Gross Inefficiency (undue delay) in connection with Civil Case No. Q-00-41263 (Julian Espiritu, Jr., represented by Attorney-in-fact Angelita L. Espiritu v. Lily Ann Espiritu-A-Misa and Jose Mari Misa), which had been raffled to Judge Arenas’ sala. [Rollo citations in original record]

Relevant Prior Civil Case History (Subject Case)

Judge Arenas promulgated a Decision dated July 13, 2010 in favor of complainant, awarding inter alia five-sixths (5/6) of the property to complainant. [Decision dated July 13, 2010, Rollo pp. 15–21]
The subject decision was appealed to the Court of Appeals (CA) and thereafter to the Supreme Court (the Court), where Judge Arenas’ Decision was essentially affirmed. [CA Decision dated October 30, 2012; CA Resolution dated July 17, 2014; Rollo pp. 24–47]
The appellate rulings attained finality, with Entries of Judgment dated November 25, 2014 and February 3, 2015 recorded in the case. [Rollo pp. 48–49]

Factual Allegations by Complainant

Complainant alleged he filed a Motion for Execution as early as July 9, 2015 to commence execution on the final decision. [Rollo p. 51–56; complainant’s allegations at Rollo p. 378]
Complainant contended that Judge Arenas resolved that motion only almost three years later by an Order dated July 6, 2018, and that such delay constituted undue delay warranting administrative sanction. [Complainant’s allegation, Rollo p. 378; alleged chronology of delay]
Complainant further alleged that despite finality of the subject case, Judge Arenas entertained subsequent motions and pleadings by the defendants, set hearings thereon, and even allowed testimony by complainant and the defendants’ mother during execution proceedings, which complainant characterized as effectively reopening a final and executory judgment and tantamount to Gross Ignorance of the Law. [Rollo pp. 378–379]

Judge Arenas’ Comment and Account

Judge Arenas filed a Comment seeking dismissal of the complaint for lack of merit and disputed the factual chronology asserted by complainant.
With respect to the Motion for Execution, Judge Arenas asserted that the motion was dated July 20, 2015 and was resolved by Order dated August 31, 2016, and that the Writ of Execution was issued on August 18, 2017—facts relied upon to show he did not unduly delay that particular motion. [Judge’s Comment, Rollo pp. 129–133; Rollo pp. 379–382]
Judge Arenas further maintained that any delay in execution proceedings was largely attributable to subsequent pleadings, motions, resettings of hearings, and other incidents initiated by the parties, rather than attributable to him; he also averred he repeatedly cautioned the defendants against prolonging execution. [Judge’s Comment, Rollo pp. 379–383]
On the charge of gross ignorance of the law, Judge Arenas acknowledged the general rule that issuance of the writ of execution is ministerial when a decision is final and executory, but stated there are exceptions and that he considered the defendants’ succeeding pleadings and motions insofar as they were connected with the motion for execution. [Judge’s Comment, Rollo pp. 382–383]

Office of the Court Administrator (OCA) Report and Recommendation

OCA Memorandum dated January 4, 2021 recommended:
- Dismissing the charge of gross ignorance of the law as judicial in nature.
- Finding Judge Arenas administratively liable for undue delay in rendering an order and fining him PHP 15,000.00, with the amount to be deducted from his compulsory retirement benefits. [OCA Memorandum, Rollo pp. 377–387]
OCA’s reasons:
- Acts of entertaining subsequent pleadings/motions and allowing testimony fell within judicial discretion; alleged errors were to be addressed by judicial remedies (appeal/certiorari) and not by administrative complaint. [OCA reasoning, Rollo p. 385]
- With respect to complainant’s Motion for Execution dated July 9, 2015, OCA found records showing resolution by Order dated August 31, 2016 and thus no clear basis to ascribe undue delay to Judge Arenas for that motion; records did not clearly show when the motion was submitted for resolution or when the last pleading was filed. [OCA finding, Rollo pp. 383–384]
- OCA found Judge Arenas guilty of undue delay only for defendants’ Motion to Enjoin the Implementation of the Writ of Execution filed November 9, 2017, because the last pleading (Rejoinder) was filed December 7, 2017 and the incident was resolved only on July 6, 2018 — seven months after submission — exceeding the three-month limit of Article VIII, Section 15(1) for “other lower courts.” [OCA finding, Rollo pp. 385–386]

Issues Presented to the Court

Whether respondent Presiding Judge Santiago M. Arenas should be held administratively liable for the acts complained of, specifically:
- Whether Judge Arenas is guilty of Gross Ignorance of the Law in entertaining subsequent pleadings and testimonies during execution proceedings of a final and executory decision; and
- Whether Judge Arenas is administratively liable for undue delay in resolving matters incident to the execution proceedings, particularly the Motion to Enjoin the Implementation of the Writ of Execution filed November 9, 2017.

Applicable Rules, Constitutional Provision, and Jurisprudential Principles Applied

Rule 140 of the Rules of Court, as further amended by A.M. No. 21-08-09-SC (approved En Banc Feb 22, 2022; publication requirement complied April 3, 2022), applies to all pending and future administrative disciplinary cases involving judiciary personnel; Section 24 expressly affords retroactive application to pending cases. [Rule 140 amendments; Section 24 in text]
Section 26 (effectivity clause) of the Rules of Court: rules take effect following publication in the Official Gazette or in two newspapers of national circulation. [Rule 140, Section 26 as cited]
Section 2(2) of the Rules: a respondent’s supervening retirement does not preclude continuation of disciplinary proceedings once jurisdiction has attached. This principle is supported by case law: Office of the Court Administrator v. Fuensalida; Baquerfo v. Sanchez. [Rollo citations to Fuensalida and Baquerfo]
Article VIII, Section 15(1) of the 1987 Consti