Case Summary (A.M. No. 14-11-350-RTC)
Findings of the Audit
The audit revealed several deficiencies: 69 cases pending decision beyond the mandated 90-day period, 33 cases with unresolved incidents, and 155 cases that had become dormant. Specifically notable were irregularities in key criminal cases, including erroneous orders that contravened the Revised Rules of Criminal Procedure.
Report Inaccuracies
Inaccuracies in a report submitted by the RTC were highlighted, including the exclusion of cases already decided and others pending action. These omissions were regarded as violations of the guidelines stipulated in Administrative Circular No. 61-2001. Furthermore, the audit team found that the docket records were inadequately maintained, and there were failures to create essential judgment and execution books.
Impropriety of Personal Involvement
The audit noted the inappropriate involvement of Judge Macabaya's wife in court operations, an action he defended as assistance but which created a perception of interference in judicial functions.
Response to Audit Observations
Subsequently, Atty. Taumaturgo U. Macabinlar, Clerk of Court V, submitted an action plan aimed at addressing the audit findings. However, the proposed plan lacked specificity and measurable outcomes, prompting the audit team to recommend revisions to ensure effectiveness and accountability.
Continued Non-Compliance
Despite being reminded multiple times of the need for compliance with the audit team's directives, Judge Macabaya exhibited a pattern of non-compliance that involved submitting incomplete documents months beyond the deadlines and failing to take adequate actions on unresolved cases, which collectively amounted to administrative inefficiency.
Court’s Intervention
Ultimately, on December 1, 2014, the Court directed Judge Macabaya to show cause for potential disciplinary action concerning his repeated failures. In addition, he was temporarily relieved of some judicial duties, and his salaries were withheld pending compliance with court orders.
Motion for Reconsideration
In early 2015, Judge Macabaya filed motions arguing that the penalties were unjust and that his due process rights were violated. He claimed the delays were partly due to an influx of new cases and a lack of records following a fire at the Hall of Justice.
Findings of the Office of the Court Administrator (OCA)
The OCA concluded that Judge Macabaya had been guilty of gross misconduct and gross ignorance of the law, recommending his dismissal and forfeiture of retirement benefits. This recommendation cited a lack of adequate responses to the audit findings and ongoing inefficiencies.
Ruling of the Cour
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Background of the Case
- The administrative matter originated from a judicial audit conducted on March 12 and 13, 2013, in Branch 20 of the Regional Trial Court (RTC) of Cagayan de Oro City, presided by Judge Bonifacio M. Macabaya.
- An audit team examined 573 cases and discovered numerous discrepancies, including:
- 69 cases submitted for decision that remained undecided beyond the mandated 90-day period.
- 33 cases with pending incidents unresolved past the reglementary period.
- 155 cases that were dormant and unacted upon for a considerable time.
Findings of the Audit
- The audit identified specific irregularities in several cases:
- Criminal Case No. 2001-888: Judge Macabaya issued an order requiring the accused to secure a new bond despite existing regulations stating that a bond remains effective until the case is resolved.
- Criminal Case Nos. 2000-260 and 2000-316, and Criminal Case Nos. 2002-098 and 2002-100: Orders were issued directing the Branch Clerk of Court to receive evidence through ex-parte hearings, which contravenes the Revised Rules of Criminal Procedure.
- The audit also noted inaccuracies in the RTC's reporting, including:
- Failure to report 43 cases submitted for decision and 13 unresolved motions.
- Premature reporting of six cases as submitted for decision without proper documentation.
- The audit team found that the docket books for civil cases were not regularly updated, and essential books like the Judgment Book and Execution Book were missing.
Role of Judge Macabaya's Wife
- The audit revealed that Judge Macabaya's wife was actively involved in court proceedings, despite not being a court employee.
- Judge Macabaya acknowledged her involvement and claimed it helped him focus