AM 01 1608 RTJ; (January, 2001) (Digest)
A.M. No. 01-1608-RTJ. January 16, 2001. SANGGUNIANG BAYAN OF TAGUIG, METRO MANILA, complainant, vs. Judge SANTIAGO G. ESTRELLA, respondent.
FACTS
This administrative case arose from Election Protest No. 144. Respondent Judge Santiago G. Estrella presided over the mayoral election protest filed by Ricardo D. Papa, Jr. against Isidro B. Garcia. After the revision of ballots, Papa filed a “Motion for Technical Examination” objecting to over 5,000 ballots as allegedly written by one or two persons, which the judge granted but Papa later withdrew. A final revision report noted Papa’s objections to 11,290 ballots. Subsequently, sua sponte, respondent judge ordered the NBI to examine the contested ballots. After the NBI report was submitted, Judge Estrella denied Garcia’s motion to be furnished a copy, reasoning the examination was court-initiated. He also transferred all ballot boxes to another branch for a related case.
Judge Estrella then set the promulgation of judgment. Garcia secured a COMELEC Temporary Restraining Order (TRO). After the TRO expired, the judge granted Papa’s motion for immediate promulgation three days before its scheduled hearing, setting a new promulgation date. The COMELEC issued another order directing respondent to give both parties access to the NBI reports before promulgation. On promulgation day, respondent gave Garcia’s counsel only five minutes to review the voluminous NBI reports (70 pages total) before rendering a decision in favor of Papa.
ISSUE
Whether respondent Judge Santiago G. Estrella is administratively liable for serious misconduct, partiality, and negligence in handling Election Protest No. 144.
RULING
Yes, respondent judge is guilty of serious misconduct, partiality, and inexcusable negligence. The Supreme Court emphasized that a judge’s conduct must be free from any appearance of impropriety to preserve public confidence in the judiciary. Respondent’s actions collectively demonstrated bias and a lack of impartiality. His sua sponte order for an NBI examination, after the protestant had withdrawn a similar motion, was irregular. His refusal to furnish Garcia a copy of the NBI report, coupled with the abrupt transfer of ballot boxes that made independent verification impossible, deprived Garcia of due process. The grant of a motion for immediate promulgation three days before its hearing, effectively preempting Garcia’s opportunity to be heard, was a clear procedural shortcut indicating haste to decide for one party.
Furthermore, allowing only a five-minute review of complex technical reports before promulgation rendered the COMELEC’s order for access meaningless and was a blatant denial of a fair opportunity to contest the evidence. The Court also found credence in the COMELEC’s observation that the NBI’s examination of over 14,000 ballots in two months was practically impossible to accomplish with scientific accuracy, casting doubt on the integrity of the evidentiary basis for the decision. These acts, viewed in totality, constituted serious misconduct and inexcusable negligence, violating the Code of Judicial Conduct. Judge Estrella was fined P20,000.00.