A.M. No. 44-MJ. August 30, 1974.
Amy O. Laurente, complainant, vs. Municipal Judge Manuel Blanco of Mambusao, Capiz, respondent.

FACTS

Complainant Amy O. Laurente filed an administrative complaint against respondent Municipal Judge Manuel Blanco for alleged inaction and indifference in Criminal Case No. 476 for Slander by Deed. The regular judge of the Municipal Court of Sapian, Judge Felix A. Villanoy, inhibited himself because the accused was his cousin. Consequently, respondent Judge Blanco, the Municipal Judge of Mambusao, was designated to hear, try, and decide the case. After trial, Judge Blanco rendered a decision of conviction on June 15, 1970, and furnished a copy to the complainant. The accused orally gave notice of appeal and was granted five days to file an appeal bond, but he never did.
The complainant alleged that Judge Blanco failed to implement his decision after July 15, 1970, as the accused was not arrested and the records were not transmitted to the Court of First Instance. It was only on March 10, 1972, after learning the bond was not filed, that Judge Blanco issued an order for the accused’s arrest and the transmittal of records. The investigation also revealed a second charge: Judge Blanco failed to make mandatory entries in the criminal docket book for the case as required by the Rules of Court.

ISSUE

The issues are: (1) Whether respondent Judge Blanco is administratively liable for failing to implement his decision and ensure the transmittal of records after rendering judgment; and (2) Whether he is liable for negligence in not making the required docket entries.

RULING

The Supreme Court exonerated Judge Blanco on the first charge but found him negligent on the second, resulting in an admonition. On the charge of inaction, the Court agreed with the Investigating Judge that respondent had fully performed his designated duty to “hear, try and decide” the case upon rendering the decision. Subsequent duties, such as accepting the appeal bond, ordering arrest for non-filing, and transmitting records, pertained to the regular presiding judge of the court, Judge Villanoy. The basis for Judge Villanoy’s inhibition—his relationship with the accused—did not legally preclude him from performing these purely ministerial post-judgment functions. Therefore, complainant’s demand for action from respondent after the decision was without legal basis.
However, the Court found respondent administratively liable for negligence concerning the docket. Section 18, Rule 136 of the Revised Rules of Court mandates a judge to ensure the docket book contains specific entries, including the plea, trial minutes, witnesses, judgment, and notice of appeal. While the entries could be made by court personnel under the judge’s supervision, the responsibility for their completion ultimately rests with the presiding judge. Respondent’s designation to try the case in another municipality did not excuse this duty. His failure constituted negligence in the performance of a judicial duty, warranting administrative sanction. Accordingly, the Court admonished Judge Blanco to be more careful in fulfilling all duties, even when acting in a temporary capacity.