Case Summary (A.M. No. RTJ-16-2460)
Factual Background of the Complaint
On October 2, 2012, Judge Felicen ordered the parties to submit pre-trial briefs for a hearing scheduled on February 5, 2013. After Judge Felicen inhibited himself, the case was raffled to Judge Cabrera-Faller. She set a clarificatory hearing for March 19, 2013, later rescheduling it to May 22, 2013, due to her seminar commitments. Pre-trial was subsequently set for August 14 and 29, 2013, but was delayed as the case had been referred for mediation. The Mediator’s Report was received on September 18, 2013. However, the plaintiffs submitted their pre-trial brief late (on August 27, 2013), leading to a motion by the Spouses Dumdum to expunge it, which remained unresolved for nearly two years.
Allegations and Defense
The complaint alleges gross ignorance of the law, gross inefficiency, and delay. Respondents denied these allegations, asserting they acted appropriately and that delays were due to continuing procedures like mediation. Judge Cabrera-Faller contended that the motions were handled as they should have been, and Suluen argued she was not responsible for the delays as an OIC/Legal Researcher.
Evaluation by the Office of the Court Administrator (OCA)
The OCA reviewed the complaint and found insufficient evidence for gross ignorance of the law. However, it determined that Judge Cabrera-Faller was guilty of gross inefficiency and delay in the administration of justice for failing to act on the pending motion for almost two years. The OCA exonerated Suluen, stating that the responsibility for resolving the motion rested solely with Judge Cabrera-Faller.
Court's Ruling on the Allegations
The Court concurred with the OCA's findings, specifically noting that the complainants failed to prove allegations of gross ignorance of the law against both respondents. The Court emphasized that no acts of bad faith or corruption were demonstrated in their behavior. However, the Court found Judge Cabrera-Faller responsible for the significant delay in processing the motion, which constituted gross inefficiency in her role.
Judicial Standards and Delays
The ruling underscored the constitutional mandate and judicial conduct requiring judges to decide cases promptly to avoid denying justice. It was reiterated that judicial officers must exercise diligence and a commitment to the timely administration of justice, failing which the Court would take appropriate administrative actions.
Findings on Judge Cabrera-Faller and Suluen
The Court found that Judge Cabrera-Faller's failure to decide the motion represented a gross inefficiency and unreasonable delay in judicial proceedings, warrantin
...continue readingCase Syllabus (A.M. No. RTJ-16-2460)
Case Background
- This case involves a complaint lodged by Atty. Jerome Norman L. Tacorda and Leticia Rodrigo-Dumdum against Judge Perla V. Cabrera-Faller and Ophelia G. Suluen, both officers of Branch 90, Regional Trial Court (RTC) in Dasmariñas City, Cavite.
- The complaint alleges gross ignorance of the law, gross inefficiency, delay in the administration of justice, and impropriety.
Relevant Facts
- The underlying case is Civil Case No. 398810, involving Sunny S. Salvilla and others against the Spouses Edwin Dumdum and Leticia R. Dumdum.
- Initially presided over by Judge Fernando L. Felicen of Branch 20, RTC Imus, Cavite, Judge Felicen inhibited himself on January 16, 2013. The case was subsequently assigned to Judge Cabrera-Faller.
- Judge Cabrera-Faller scheduled a clarificatory hearing, originally set for March 19, 2013, but postponed it to May 22, 2013, due to her attendance at a seminar.
- The case was set for a pre-trial on August 14 and 29, 2013, but was suspended pending the receipt of a Mediator's Report, which was received on September 18, 2013.
- Plaintiffs filed a pre-trial brief belatedly on August 27, 2013, prompting a motion to expunge by the Spouses Dumdum's counsel on September 3, 2013.