AM 1762; (March, 1980) (Digest)
G.R. No. A.M. No. 1762 March 31, 1980
MANUEL BEDUYA, complainant, vs. HON. PANFILO ALPUERTO, Acting City Judge of Danao City, respondent.
FACTS
Manuel Beduya filed a verified complaint charging Acting City Judge Panfilo Alpuerto with inefficiency and incompetence regarding Criminal Case No. 2323 for grave coercion. The complaint specified four counts: (1) an unreasonable delay of over two years and seven months in promulgating the judgment after the case was submitted for decision, violating the constitutional mandate; (2) failure to make a finding on conspiracy despite two accused being charged; (3) apparent partiality by not pronouncing on the third element of grave coercion; and (4) ignoring the directive to convict for a lesser offense. Respondent Judge admitted the delay but attributed it to ill-health from performing duties in two judicial stations. He defended his judgment, arguing the crime was not proven, thus negating the need for conspiracy findings or conviction for a lesser offense.
During the investigation by the Executive Judge, complainant Beduya manifested he was no longer interested in prosecuting the case and requested its dismissal. Consequently, the Investigating Judge recommended dismissal due to the complainant’s lack of interest and failure to substantiate the charges.
ISSUE
Whether respondent Judge is administratively liable despite the complainant’s desistance and the recommendation for dismissal.
RULING
Yes, the respondent Judge is administratively liable for undue delay in rendering judgment. The Supreme Court emphasized that an administrative complaint against a judge is a public concern, and the complainant’s desistance does not automatically warrant dismissal, especially when a prima facie case is established. The first count of undue delay was sufficiently proven by the respondent’s own admission and the Clerk of Court’s certification, confirming the judgment was promulgated on September 26, 1977, over two years and seven months after the case was submitted for decision on February 11, 1975. This clearly violated the constitutional and statutory mandate to decide cases within ninety days.
The Court found the respondent’s excuse of ill-health due to dual assignments insufficient to justify such an extensive delay, as judges are obligated to manage their caseloads and request extensions if necessary. The other charges regarding the judgment’s merits were deemed judicial in nature, pertaining to the exercise of adjudicatory discretion, and thus not proper subjects for administrative sanction absent proof of bad faith or gross ignorance. However, the delay constituted inefficiency warranting disciplinary action. Accordingly, the Court reprimanded Judge Alpuerto and admonished him that a repetition would be dealt with more severely.
