G.R. No. A.M. RTJ No. 90-474 & RTJ No. 90-606. February 7, 1992. CLEMENCIO C. SABITSANA, JR., complainant, vs. JUDGE ADRIANO R. VILLAMOR, RTC, Branch 16, Naval, Leyte, respondent.
FACTS

This is a resolution on respondent Judge Adriano R. Villamor’s motion for reconsideration of the Court’s Per Curiam Decision dated October 4, 1991, which dismissed him from service. The original decision found him guilty of multiple administrative infractions consolidated in two cases. In A.M. No. RTJ-90-474, he was charged with making untruthful statements in his Certificates of Service, inexcusable negligence and gross inefficiency concerning unresolved cases and missing court records, and indifference to Supreme Court directives. In A.M. No. RTJ-90-606, which was treated as a supplemental charge, he was found guilty of serious misconduct for exerting undue interest in a pending criminal case before an inferior court he supervised.

ISSUE

Whether the grounds raised in the motion for reconsideration warrant a reversal or modification of the penalty of dismissal imposed on the respondent judge.

RULING

The Court denied the motion for reconsideration but modified the penalty’s accessory clauses. The respondent’s arguments did not absolve him of liability. Regarding the unresolved cases, his claims of inheriting a heavy docket and facing administrative obstacles did not excuse his failure to decide cases within the reglementary period and his submission of inaccurate Certificates of Service, for which he bore personal responsibility. Concerning the missing records, while external factors were cited, ultimate accountability rested with him as the presiding judge. On the charge of undue interest, the Court found no denial of due process. The investigation provided him full opportunity to confront evidence, including the affidavit of MCTC Judge Pitao and his own handwritten note concerning the People v. Lipango case, which substantiated the violation of judicial ethics by attempting to influence a subordinate court.
The legal logic is that a judge’s duties are non-delegable; administrative inefficiencies and staff problems do not relieve a judge of the fundamental responsibilities of ensuring the prompt disposition of cases, maintaining the integrity of court records, and exhibiting absolute impartiality. The act of interfering in a lower court’s case constitutes grave misconduct that erodes public confidence in the judiciary. While the Court acknowledged some mitigating efforts, the cumulative weight of the violations, particularly the undue influence, demonstrated unfitness for judicial office. Consequently, the penalty of dismissal with prejudice to re-employment was upheld. However, the Court compassionately amended the decision to allow him to enjoy accrued leave benefits and corrected his name by removing “Jr.”