Case Summary (G.R. No. L-27152)
Antecedents of the Complaint
The administrative case originated from Judge Maddela and Judge Ligaya's letter-complaint filed on October 4, 2011. They alleged that Judge Pamintuan failed to perform his duty to solemnize marriages of applicants assigned to him, citing his frequent absences due to health issues. They contended that this non-compliance amounted to shirking from judicial duty as per OCA Circular No. 87-2008, which mandates judges to adhere strictly to the protocols of solemnization raffles unless valid reasons are provided.
Response from the Respondent
In a letter-comment dated February 8, 2012, Judge Pamintuan denied the allegations, arguing that his absences were due to genuine health concerns, including hypertension and needed surgery. He claimed all his leave applications were approved by the Executive Judge and that he resumed work shortly afterward.
Judicial Audit and Findings
Following an OCA directive, a judicial audit was conducted in January 2015, revealing complaints against Judge Pamintuan from fellow judges and court personnel, and documenting various allegations, including bribery, conflicts of interest, and inefficiency in case management. The audit concluded that Judge Pamintuan unjustifiably failed to manage his cases, with a significant percentage awaiting resolution beyond the mandated time frame.
Allegations of Bribery
The allegations of bribery surfaced after Executive Judge Paradeza submitted an affidavit detailing an incident where Judge Pamintuan purportedly offered him money to influence a court ruling. This claim was corroborated by statements from court personnel present during the incident.
Investigating Justice's Report
In a report submitted by the investigating Justice, findings included:
- Undue Delay: Judge Pamintuan was found guilty of delaying decisions beyond the regulatory period.
- Absences: His frequent absences were noted as not all covered by leave applications, thus constituting shirking from duty.
- Bribery: The investigating Justice recommended the dismissal of the bribery charge due to insufficient evidence.
- Conflict of Interest: Certain activities, including fundraising events, were recognized as violations of judicial conduct guidelines.
OCA's Recommendations
The OCA recommended that Judge Pamintuan be dismissed from service for gross misconduct and inefficiency, asserting a failure to uphold the integrity expected of judges. The OCA also opposed the notion that the absence of direct evidence in bribery allegations absolved him from accountability.
Court's Ruling
The court found Judge Pamintuan administratively liable for:
- Gross Misconduct: By a
Case Syllabus (G.R. No. L-27152)
Antecedents
- The administrative case originated from a letter-complaint dated October 4, 2011, submitted by Hon. Tomas Eduardo B. Maddela III and Hon. Merinnisa O. Ligaya, presiding judges of the Municipal Trial Court in Cities (MTCC) in Olongapo City.
- The complaint concerned Judge Norman V. Pamintuan, the presiding judge of the Regional Trial Court (RTC), Branch 73, for alleged failure and neglect to solemnize marriages, as mandated by Office of the Court Administrator (OCA) Circular No. 87-2008.
- Judge Maddela and Judge Ligaya reported that Judge Pamintuan was often absent or unavailable due to health issues, resulting in delays in solemnizing marriages.
- They asserted that his failure to perform his judicial duties constituted "shirking from judicial duty" as per the provisions of the OCA circular, which requires judges to participate in the raffling of marriage requests unless valid reasons are provided.
Respondent's Defense
- In his Letter-Comment dated February 8, 2012, Judge Pamintuan refuted the accusations, attributing his absences to unavoidable health issues, including hypertension and pending surgery.
- He claimed that his absences were properly documented with leave applications and medical certificates, all approved by the Executive Judge.
Judicial Audit and Complaints
- Following a resolution on October 13, 2014, the Court ordered a judicial audit of the RTC of Olongapo City, which revealed numerous c