Title
Magdadaro vs. Saniel, Jr.
Case
A.M. No. RTJ-12-2331
Decision Date
Dec 10, 2012
Judge Saniel fined P15,000 for undue delay in deciding a breach of contract case; charges of bias and ignorance dismissed.
undue delay
bias and partiality
breach of contract

Case Summary (A.M. No. RTJ-12-2331)

Factual Background of the Underlying Civil Case

Civil Case No. CEB-27778 was an action for breach of contract with damages. Complainant alleged ownership of a Nissan car with Plate No. FDX, insured with a Philippine National Bank–General Insurers Company, Inc. (PNB-GICI) Comprehensive Insurance Policy No. PC-351003 covering the period May 31, 2001 to May 31, 2002. He reported that the car met an accident at SM Megamall on September 27, 2001 and that, as required by PNB-GICI, he submitted repair estimates.

Complainant asserted that, on September 28, 2001, he had his car inspected by Nissan Distributors, Inc. (NDI), which issued Repair Estimate No. 23811 enumerating damaged parts but not the radiator tank. He also obtained a repair estimate from Bathala Marketing Industries Inc. (BMII), which likewise allegedly did not mention radiator tank damage. Complainant continued to use the car while the insurance claim awaited approval. He claimed that the car overheated on several occasions because the radiator no longer had water.

After repeated follow-ups, PNB-GICI instructed complainant to deliver the car to BMII. Complainant maintained that he informed BMII about his radiator problems and was told that the radiator was not included in the repair estimate and would require a supplemental request and approval. He averred that the repair took about a month and that he recovered the car only on December 26, 2001 after paying P9,120.50 as his share in the repair cost.

According to complainant, immediately after recovery the car overheated again after only twenty to thirty minutes. He then brought the car to Global Motors Cebu Distributors Corp. (Global Motors), where he allegedly had the radiator tank installed by BMII removed in the presence of a BMII representative. Global Motors issued a certification stating that the replacement radiator tank installed by BMII was not brand new but a reconditioned old radiator tank. Complainant claimed he paid P500.00 for Global Motors’ services and purchased a brand new replacement radiator tank from Gemini Parts Center for P9,500.00. He prayed for actual damages of P29,182.50, unearned profits of P300,000.00, moral damages of P700,000.00, exemplary damages of P700,000.00, and attorneys’ fees of P250,000.00.

Trial Court Disposition and Events Leading to the Administrative Complaint

At trial’s end, the respondent directed the parties to submit their respective memoranda and indicated that the case would be submitted for decision thereafter. Complainant submitted his memorandum on November 9, 2008, received by the RTC-Branch 20 on November 11, 2008. The respondent then rendered a Decision dated December 28, 2009, dismissing the complaint for lack of cause of action.

Complainant filed a Notice of Appeal on February 22, 2010. The RTC acted only on December 2, 2010. During the interval, complainant became dissatisfied with the RTC’s handling and filed the present administrative complaint on October 17, 2011, alleging unreasonable delay in the disposition of Civil Case No. CEB-27778, including both the delayed decision and the delayed action on the Notice of Appeal and transmittal of records.

The Parties’ Contentions in the Administrative Case

Complainant alleged that the respondent’s delay was evident because it took more than one year to decide the case from the time it was submitted for decision. He further alleged that the RTC took almost another year to act upon his Notice of Appeal and transmit the records to the appellate court. He also asserted that the respondent committed gross ignorance of the law because the decision allegedly did not properly appreciate the liabilities and obligations arising from a comprehensive car insurance contract. Finally, complainant claimed bias and partiality, alleging that the decision cited statements purportedly made by complainant which he claimed he never actually said, and that there were purported transcription or translation errors in the Transcript of Stenographic Notes (TSN) that the respondent used against him.

Complainant also raised a suspicion concerning a stamp mark “RECEIVED” on the first page of the December 28, 2009 decision, showing 12/29/09 at 8:16. He questioned why the RTC needed to receive its own decision and suspected that someone else authored the decision and submitted it for the respondent’s signature.

In his Comment dated January 17, 2012, the respondent argued that the complaint was driven by resentment, given that it followed the adverse decision. He also claimed the complaint was premature because the appeal of the December 28, 2009 decision was still pending before the Court of Appeals. According to the respondent, he could not be held liable for gross ignorance of the law because the appellate court could still affirm his ruling. As to delay regarding the Notice of Appeal, he explained that his office was understaffed, with only one clerk assigned to civil and special proceedings, and that photocopying and preparing machine copies and records for transmission took time, especially when multiple appeals were filed around the same time. However, he did not address the more than one-year delay in resolving Civil Case No. CEB-27778.

OCA Recommendation and the Court’s Procedural Management

In a Report dated March 7, 2012, the Office of the Court Administrator (OCA) recommended that the administrative complaint be re-docketed as a regular administrative matter and that the respondent be held liable for both undue delay in rendering a decision and undue delay in the proceeding, fined Twenty Thousand Pesos (P20,000.00), and warned that repetition would merit a more severe penalty.

The Court issued a Resolution dated July 4, 2012 re-docketing the matter and requiring the parties to manifest within ten days whether they agreed to submission for resolution based on the pleadings. Complainant manifested on October 2, 2012, and respondent manifested on October 11, 2012.

Challenge on Judicial Error, Bias Allegations, and Prematurity of Administrative Review

The Court addressed complainant’s challenge as, in substance, an attempt to revisit the merits of the December 28, 2009 decision. The Court noted that complainant alleged that the decision was illegal and supposedly lacked factual and legal basis, but that, through the administrative complaint, complainant effectively sought a review of the merits of a judgment that was already under judicial review.

The Court relied on settled doctrine that a judge’s erroneous interpretation of law or improper appreciation of evidence does not automatically establish administrative liability. Only judicial errors tainted with fraud, dishonesty, gross ignorance, bad faith, or deliberate intent to do an injustice are administratively sanctionable. The Court emphasized that judicial acts in good faith, absent fraud, dishonesty, or corruption, are not subject to disciplinary action even if erroneous. The complainant must show conduct clearly indicative of arbitrariness or prejudice to sustain a charge of bias and partiality.

Applying this framework, the Court held that there was no showing that the respondent was motivated by bad faith or ill motive in rendering the dismissal of Civil Case No. CEB-27778. Any error, the Court said, could be corrected through the available judicial remedy by appeal, not through an administrative case. The Court further noted that complainant had already filed an appeal docketed as SP Civil Case No. R-1105, still pending before the appellate court. For that reason, the Court ruled that an administrative complaint could not be pursued simultaneously with the judicial remedies accorded to an aggrieved party, and that administrative remedies were not alternative or cumulative to judicial review where such review had not reached finality.

Citing Salvador v. Limsiaco, Jr., Roxas v. Eugenio, Jr., and Flores v. Abesamis, the Court reiterated that disciplinary proceedings and criminal actions against judges are not substitutes for judicial remedies. The Court maintained that the door to inquiry into a judge’s civil, criminal, or administrative liability opens only after judicial remedies are exhausted and appellate tribunals have spoken with finality. Accordingly, the Court dismissed the administrative charges for gross ignorance of the law and for alleged unjust judgment.

Legal Basis for Discipline: Constitutional Timeliness and the Duty of Prompt Disposition

While the Court dismissed the charges aimed at the correctness of the decision, it found that the record established the respondent’s liability for undue delay. The Court pointed to Section 15(1), Article VIII of the 1987 Constitution, which mandates that cases or matters filed with lower courts must be decided or resolved within three months from the date submitted for decision or resolution. The Court treated rules fixing time periods as indispensable to prevent needless delays and held them mandatory.

The Court also invoked the New Code of Judicial Conduct for the Philippine Judiciary, particularly Canon 6, Section 5, requiring judges to deliver reserved decisions efficiently, fairly, and with reasonable promptness. It further cited Administrative Circular No. 1 dated January 28, 1988, which enjoined magistrates to observe scrupulously the constitutional periods and to act promptly on motions and interlocutory matters. The Court reiterated that justice delayed undermines faith in the judiciary and that judges should seek extensions from the Court rather than letting delays accumulate without justification.

Findings of Undue Delay in Rendering the Decision and Acting on the Appeal

The Court found that complainant submitted his memorandum on November 11, 2008, but the respondent rendered the decision only on December 28, 2009. The Court held that the respondent failed to decide Civil Case No. CEB-27778 within the three-month constitutional period. The Court also noted the absence of any showing that the respondent at

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