AM MTJ 98 1159; (August, 1998) (Digest)
G.R. No. MTJ-98-1159 August 3, 1998
LETICIA G. MATIAS, complainant, vs. JUDGE SERGIO A. PLAN, Municipal Trial Court, Cauayan, Isabela, respondent.
FACTS
Leticia G. Matias filed an administrative complaint against Judge Sergio A. Plan for undue delay in resolving Criminal Case No. 95-2424 for Damage To Property Through Reckless Imprudence. The case stemmed from a March 25, 1995 incident where complainant’s van was sideswiped. The complaint was filed on April 31, 1995, and the case was raffled to respondent judge. The preliminary investigation was conducted on May 16, 1995. The first hearing was on July 31, 1995, where the prosecution presented evidence. The trial involved multiple postponements, many initiated by the prosecution. The defense rested its case on November 12, 1996, after an ocular inspection, and the case was submitted for decision. Complainant filed the administrative complaint on November 4, 1996. Respondent judge rendered a decision on February 10, 1997, promulgated on March 5, 1997. The investigating judge, Executive Judge Artemio R. Alivia, found respondent judge very lax in granting postponements, allowing a simple case to drag for one and a half years, and found violations of the rule limiting postponements to thirty days. The Office of the Court Administrator adopted these factual findings.
ISSUE
Whether respondent Judge Sergio A. Plan should be administratively penalized for undue delay in the disposition of Criminal Case No. 95-2424, specifically for failure to comply with the mandatory continuous trial system.
RULING
Yes, respondent judge is administratively liable. The Supreme Court imposed a fine of P1,000.00 on respondent judge for failure to comply with the rule on mandatory continuous trial. The trial in the criminal case exceeded the three-month period prescribed by Administrative Circular Nos. 4 and 1-89 without authorization from the Chief Justice. Respondent judge was very lenient in granting postponements, some exceeding the thirty-day period allowed by the Rules, contrary to the strict policy on postponements mandated by the circulars. While no malice or bad faith was found, such leniency frustrates the speedy administration of justice. The Constitution guarantees the right to a speedy disposition of cases, and judges are mandated to adhere strictly to the continuous trial system guidelines to ensure expeditious resolution of cases.