A.M. No. 104-MJ. January 30, 1976. MAURICIO REGASPI and ELIAS REYES, complainants, vs. JUDGE EDILBERTO CASTILLO, Municipal Court of Taguig, Rizal, respondent.
FACTS:

Complainants Mauricio Regaspi and Elias Reyes charged Judge Edilberto Castillo with dishonesty, grave misconduct, gross negligence, and ignorance of the law. The complainants were the complaining witnesses in three criminal cases for serious physical injuries (Criminal Cases Nos. 1443, 1444, 1445) and the accused in two related cases for less serious physical injuries (Criminal Cases Nos. 1446, 1447), all pending before the respondent’s court. These cases were set for a joint hearing. After several postponements agreed upon by the parties, the cases were repeatedly reset due to the non-appearance of counsel.
The complainants’ original counsel, Atty. Jaime Nuevas, died. During hearings where parties appeared without lawyers, Judge Castillo advised them to engage new counsel and warned that continued non-appearance of counsel could lead to dismissal for failure to prosecute. Eventually, on September 26, 1972, upon motion of the opposing counsel and due to the continued absence of legal representation for the prosecution, Judge Castillo dismissed Criminal Cases Nos. 1443, 1444, and 1445 for failure to prosecute. He then appointed Atty. Irineo Bunyi as counsel de officio for the complainants in their capacity as accused in the two remaining cases. Later, on October 24, 1972, upon motion of Atty. Bunyi and due to the non-appearance of the fiscal and private prosecutor, Judge Castillo also dismissed Criminal Cases Nos. 1446 and 1447 for failure to prosecute.

ISSUE

Whether or not Judge Edilberto Castillo is administratively liable for dismissing the criminal cases for failure to prosecute.

RULING

The Supreme Court exonerated Judge Castillo and found no merit in the complaint. The dismissal of the cases was a legitimate exercise of judicial discretion aimed at ensuring the speedy administration of justice. The Court emphasized that the respondent judge did not act arbitrarily. Before dismissing the cases, he afforded the parties ample opportunity to proceed. He granted multiple postponements, advised the complainants to secure new counsel after their lawyer’s death, and issued repeated warnings that the cases would be dismissed if prosecution failed due to absence of counsel. His actions demonstrated due regard for the rights of the accused to a speedy trial. Furthermore, his impartiality was evident as he dismissed both the charges filed by the complainants and the counter-charges against them on the same ground of failure to prosecute. His appointment of a counsel de officio for the complainants in their cases as accused further showed his commitment to procedural fairness. Therefore, his actions were within the bounds of his judicial authority and duty.