G.R. No. A.M. No. MTJ-25-043, February 25, 2025
RE: JOINT REPORT DATED 23 OCTOBER 2023 ON ANONYMOUS COMPLAINT AGAINST HON. JOSEPHINE G. BAUTISTA-NICHOLS, PRESIDING JUDGE, 4TH MUNICIPAL CIRCUIT TRIAL COURT, LUMBAN-KALAYAAN, LUMBAN, LAGUNA.

FACTS

An anonymous complaint was filed against respondent Judge Josephine G. Bautista-Nichols, Presiding Judge of the 4th MCTC, Lumban-Kalayaan, Laguna, alleging: (1) abuse of judicial position to influence land-related cases in Sta. Maria, Bulacan; and (2) improper attendance by frequently being absent from in-person hearings and primarily conducting hearings online. The Office of the Court Administrator (OCA) conducted a judicial audit. The first audit team discovered 20 cases (criminal, civil, and small claims) submitted for decision but pending beyond the reglementary period. The records of one civil case were with the Judge for decision writing during the audit. The second team found the land-grabbing allegation baseless, as barangay officials in Sta. Maria, Bulacan, had no knowledge of any pending land case involving the Judge and were unaware she was a judge. The audit confirmed the Judge conducted videoconference hearings (VCH) from her residence in Sta. Maria, Bulacan, outside her judicial region, and was not wearing her judicial robe during an online hearing. The court used Google Meet instead of the required Microsoft Teams due to poor internet, without coordination, resulting in no auto-recording. Other observations included: unpaginated case records; Certificates of Arraignment signed by the Judge instead of the Clerk of Court; and a general docket not properly maintained.

ISSUE

Whether Judge Josephine G. Bautista-Nichols is administratively liable for the infractions discovered during the judicial audit.

RULING

Yes, Judge Bautista-Nichols is administratively liable. The Supreme Court found her guilty of Gross Misconduct, Gross Ignorance of the Law, and Violation of Supreme Court Rules, Directives, and Circulars. The failure to decide the 20 cases within the reglementary period constitutes Gross Misconduct and Gross Ignorance of the Law. Conducting VCH from outside the court’s territorial jurisdiction and without wearing judicial attire violates rules on court decorum and A.M. No. 20-12-01-SC. Using an unauthorized platform (Google Meet) for VCH breaches administrative circulars. The procedural lapses in court records (unpaginated records, improperly signed certificates, unmaintained docket) demonstrate neglect. The mitigating circumstances of her length of service, acknowledgment of infractions, and the court’s high clearance rate were considered. The Court imposed a fine of Forty Thousand Pesos (P40,000.00), deductible from retirement benefits, with a stern warning.