G.R. No. A.C. No. 190-J March 21, 1974
THE SECRETARY OF JUSTICE, complainant, vs. HON. VICENTE P. BULLECER, respondent.

FACTS

The Secretary of Justice filed an administrative complaint against Judge Vicente P. Bullecer for serious inefficiency and misconduct. The inefficiency charge stemmed from his failure to decide Civil Case No. 4571 and two criminal cases within the 90-day period mandated by the Judiciary Act. The misconduct charge was based on his submission of monthly certificates of service falsely attesting that all cases submitted for 90 days or more had been decided, which allowed him to collect his salary.
In his defense, Judge Bullecer explained that the record of Civil Case No. 4571 was misplaced after his court was transferred from Davao City to Mati, causing him to honestly overlook it until it was found in October 1970, after which he decided it in December 1970. Regarding the two criminal cases, he insisted they were decided within the 90-day period, counting from the expiration of the time granted for the filing of memoranda after the transcripts were received by the parties, not from the initial date the hearings were concluded.

ISSUE

Whether respondent Judge Bullecer should be held administratively liable for serious inefficiency and misconduct.

RULING

The Court, adopting the report of Investigating Justice Arsenio Solidum, exonerated Judge Bullecer from the charges of serious misconduct and inefficiency, but issued an admonition. On the charge of serious misconduct for the false certification, the Court found that the falsehood was not intentional. It resulted from carelessness and reliance on subordinates during the court’s physical transfer, which led to the misplacement of the case record. Applying the standard from In re Horrilleno, misconduct warranting disciplinary action must be “serious”—important and weighty, not merely trifling or arising from negligence. The judge’s conduct did not meet this high threshold.
Regarding inefficiency, the Court found the explanation for the delay in the civil case reasonable due to the misplaced record. For the criminal cases, the Court accepted the judge’s method of counting the 90-day period from the deadline for memoranda, which was within the permissible discretion of a trial judge in managing his docket. Thus, the delay did not constitute the “serious inefficiency” contemplated by law. However, the Court admonished the judge to exercise greater care in preparing his certificates of service and in monitoring his docket to prevent future oversight, emphasizing the paramount importance of prompt case disposition to maintain public faith in the judiciary.