Office of the Court Administrator, Complainant, vs. Presiding Judge Filpia D. Del Castillo, MTC, Maayon, Capiz, Respondent.
FACTS
A judicial audit of the MTCC, Branch 2, Roxas City, Capiz, revealed that the records of Criminal Case No. 97-10140 were not with the court, as they had been “borrowed” by respondent Judge Filpia D. Del Castillo, then Acting Presiding Judge of that branch, and brought to her current court, the MTC of Maayon, Capiz. The audit team reported that Judge Del Castillo had issued an Order dated February 3, 2004, deeming the defense’s formal offer of exhibits waived and giving the prosecution 15 days to submit a memorandum, after which the case would be deemed submitted for decision. The Office of the Court Administrator (OCA) required Judge Del Castillo to explain whether she observed the guidelines in Mabunay regarding cases submitted for decision. In her response, she stated she presumed the incumbent judge, Judge Elias A. Conlu (appointed February 9, 2004), had inventoried and returned the case records to her for decision, but she was uncertain if the case was actually submitted for decision and whether Mabunay applied. Judge Conlu commented that the record was returned to him without any action since Judge Del Castillo’s last order and that she appeared not to know what to do with the case. The OCA recommended holding Judge Del Castillo liable for delay, noting the case was deemed submitted on February 15, 2004, and she had 90 days to decide it, but she failed to do so by April 15, 2004. Judge Del Castillo later manifested that she had dismissed the criminal case on June 12, 2008.
ISSUE
Whether Judge Filpia D. Del Castillo is administratively liable for her handling of Criminal Case No. 97-10140.
RULING
Yes, Judge Del Castillo is guilty of simple misconduct. The Supreme Court found insufficient evidence to conclude she was in delay in deciding the case, as it was unclear when Judge Conlu actually assumed office and whether he could have taken over the case administratively before completing his orientation. However, the Court held that Judge Del Castillo exhibited ignorance of the law and procedure by failing to properly resolve the case’s status after her February 3, 2004 Order, by unnecessarily keeping the case records for years, and by failing to decide or transfer the case promptly. Her actions constituted simple misconduct for violating the Code of Judicial Conduct, which requires judges to be faithful to the law and maintain professional competence. The Court imposed a fine of ₱20,000.00 with a stern warning.
