A.M. No. RTJ-00-1569. November 22, 2000. HON. MELCHOR E. BONILLA, Presiding Judge of the 16th MCTC, Jordan-Buenavista-Nueva Valencia, Province of Guimaras, complainant, vs. HON. TITO G. GUSTILO, Executive Judge, Branch 23, Regional Trial Court, Iloilo City, respondent.
FACTS

Complainant Judge Melchor E. Bonilla charged respondent Executive Judge Tito G. Gustilo with Undue Delay and Grave Abuse of Authority. The delay pertained to Judge Gustilo’s failure to submit his report and recommendation in an administrative case, A.M. No. MTJ-94-923, where Judge Bonilla was the respondent. The Supreme Court had directed Judge Gustilo to complete the investigation and report within 60 days. Despite the investigation being terminated on August 16, 1996, Judge Gustilo submitted his report only on June 18, 1998, which was received by the Court on August 11, 1998—a delay of one year and ten months from the last hearing. Judge Bonilla also alleged Grave Abuse of Authority, claiming Judge Gustilo ordered his relief and detail to another court without Supreme Court authority, causing him personal inconvenience and hardship, including injuries from a vehicular accident while traveling to the detailed post.
In his comment, Judge Gustilo justified the delay by citing the voluminous records from the charge and countercharge between Judge Bonilla and his clerk of court, and numerous postponements. Regarding the detail, he explained it was a managerial act to separate the feuding parties to prevent prejudice to the service pending the resolution of their administrative case.

ISSUE

Whether respondent Judge Tito G. Gustilo is administratively liable for Undue Delay in resolving the administrative case and for Grave Abuse of Authority in detailing complainant Judge Melchor E. Bonilla to another court.

RULING

The Supreme Court found Judge Gustilo liable for Undue Delay but not for Grave Abuse of Authority. On the first charge, the Court emphasized that judges must perform their duties with diligence and decide matters promptly to uphold public confidence in the judiciary. Justice delayed is justice denied. While the Court acknowledged the voluminous records, it ruled this did not justify the inordinate delay of nearly two years in submitting the report after the investigation was concluded. The fact that the report was submitted only after the filing of the instant administrative complaint indicated a lack of promptness. Thus, Judge Gustilo was ADMONISHED for undue delay, with a warning that a repetition would be dealt with more severely.
On the charge of Grave Abuse of Authority, the Court held it was without merit. An Executive Judge possesses specific administrative powers, including the authority to designate a municipal judge to try cases in other municipalities within his area of supervision in cases of absence or incapacity, effective immediately unless revoked by the Supreme Court. Judge Gustilo’s act of detailing Judge Bonilla was within this prerogative, motivated by a desire to maintain court efficiency and harmony given the ongoing conflict between Judge Bonilla and his clerk of court. Therefore, no abuse of authority was found.