G.R. No. MTJ-94-920 January 20, 1995
Agripino S. Belen, complainant, vs. Judge Santiago E. Soriano, Presiding Judge, MTC Naguilian, La Union, respondent.

FACTS

Complainant Agripino S. Belen charged respondent Judge Santiago E. Soriano with gross ignorance of the law, gross incompetence, and neglect of duty. The charges stemmed from the judge’s handling of Criminal Case No. 2431 for grave threats, which is within the exclusive original jurisdiction of the Regional Trial Court (RTC), not the Municipal Trial Court (MTC). The complainant alleged that the judge took cognizance of the case and failed to act promptly on a prosecution motion to elevate it to the proper court. The complainant also assailed the judge for issuing a warrant of arrest against him in a separate perjury case without allegedly affording him the opportunity to file a counter-affidavit.
In his defense, respondent judge explained he assumed jurisdiction over the grave threats case only because the information was filed directly by the assistant provincial fiscal. He claimed he issued an order on September 25, 1989, directing the transfer of the records to the provincial fiscal for transmission to the RTC. However, the records were misplaced following the July 16, 1990 earthquake that damaged the municipal building. The records were eventually forwarded only on August 9, 1993. Regarding the perjury case, the judge asserted he required a counter-affidavit, but the complainant instead filed a manifestation adopting his prior affidavit.

ISSUE

Whether respondent Judge Santiago E. Soriano is administratively liable for the delay in transmitting the records of a criminal case to the proper court.

RULING

Yes, the respondent judge is administratively liable for negligence. The Court, adopting the findings of the investigating Executive Judge, exonerated Judge Soriano from the charges of gross ignorance of the law and gross incompetence. The initial error of filing the information with the MTC lay with the prosecution, not the judge. However, the Court found him guilty of neglect of duty for the unreasonable four-year delay in causing the transmission of the case records to the RTC after granting the motion to elevate.
The judge’s explanation blaming the earthquake and his clerk of court for the misplacement and delay is unacceptable. A judge bears administrative responsibility for the proper management of court records and the prompt implementation of his orders. Court records are vital public documents, and their safekeeping is essential to maintaining public confidence in the judiciary. The judge cannot evade accountability by shifting blame to a subordinate, especially when the clerk of court’s testimony contradicted his own account regarding the custody of the records. This failure constitutes negligence, violating the constitutional mandate for the speedy disposition of cases. Accordingly, the Court admonished Judge Soriano and fined him Two Thousand Pesos (P2,000.00) with a stern warning.