AM 01 3 64 MTC; (December, 2001) (Digest)
A.M. No. 01-3-64-MTC, December 5, 2001
IN RE: NOTICE ISSUED BY JUDGE AGAPITO K. LAOAGAN, JR., MTC LA TRINIDAD, BENGUET
FACTS
On January 2, 2001, Judge Agapito Laoagan, Jr., Presiding Judge of the Municipal Trial Court of La Trinidad, Benguet, issued a notice unilaterally suspending all trials and hearings in his court, except for promulgations, provisional remedies, and criminal cases involving detention prisoners. He issued this suspension in anticipation of his transfer to the National Commission on Indigenous Peoples (NCIP), intending to use the period to dispose of cases already submitted for decision. He had received his NCIP appointment in December 2000 but only formally requested permission from the Chief Justice for the transfer on January 10, 2001, which was granted on February 5, 2001. The Executive Judge forwarded the suspension notice to the Office of the Chief Justice, prompting an administrative complaint. Judge Laoagan later learned his transfer was covered by an election ban, postponing it until after the May 2001 elections. He resumed full court operations only on April 1, 2001.
ISSUE
Whether Judge Agapito Laoagan, Jr. is administratively liable for issuing an unauthorized notice suspending court hearings, thereby causing undue delay in the administration of justice.
RULING
Yes, Judge Laoagan is administratively liable. The Court emphasized the fundamental judicial duty to administer justice without delay, as mandated by the Code of Judicial Conduct (Canon 1, Rule 1.02 and Canon 3, Rule 3.05). Delay erodes public confidence in the judiciary. Judge Laoagan’s act of suspending court proceedings prior to securing official authorization was precipitate and imprudent. His rationale—to clear pending decisions—did not justify effectively halting the court’s docket. The legal logic holds that a judge must ensure the continuous operation of the court; any suspension of proceedings requires proper authority and cannot be self-determined. His failure to resume sessions immediately upon learning of the postponed transfer (around March 1) until April 1 further compounded the undue delay. The Court, however, considered the mitigation that he maintained limited operations for urgent matters. Consequently, he was found liable for delay and neglect of duty and fined Two Thousand Pesos (P2,000.00).