G.R. No. MTJ-99-1227 May 9, 2000
Fernando V. Torres, complainant, vs. Judge Francisco D. Villanueva, respondent.

FACTS

Fernando V. Torres filed a civil case for annulment of a deed of sale and a real estate mortgage, and for the cancellation of eleven checks issued to Amparo Medina. Subsequently, Medina filed criminal cases against Torres for violations of B.P. 22 based on the same checks. These criminal cases were raffled to the court of respondent Judge Francisco D. Villanueva. Torres moved to suspend the criminal proceedings, arguing that the resolution of the civil case constituted a prejudicial question. The Regional Trial Court, in a petition for certiorari, granted Torres’s plea and ordered Judge Villanueva to suspend the arraignment until the civil case was resolved.
The civil case was eventually dismissed. Upon Medina’s motion to revive the criminal proceedings, set for hearing on May 9, 1997, Judge Villanueva issued an order on May 7, 1997, granting the motion and setting the arraignment without waiting for the scheduled hearing and without allowing Torres to file an opposition. Torres received the motion and the granting order on the same day. Torres filed an administrative complaint, alleging that the judge’s summary action denied him his day in court.

ISSUE

Whether respondent Judge Villanueva committed abuse of authority by granting a motion to revive criminal proceedings without conducting a hearing and without affording the accused an opportunity to be heard.

RULING

Yes, the Supreme Court found respondent Judge guilty of abuse of authority. The Court emphasized that while prompt disposition of cases is a judicial duty, it must never be pursued at the expense of procedural due process. The basic elements of notice and hearing are indispensable. Judge Villanueva’s act of resolving the motion on the very day it was filed and received, two days before its scheduled hearing, deprived the accused of a reasonable opportunity to present his side.
The Court rejected the judge’s justification based on a heavy caseload and a desire to facilitate disposition. Such reasons do not excuse the disregard of fundamental fairness. A judge must exercise patience and circumspection to avoid any imputation of bias, and a display of impatience is incompatible with judicial decorum. The Court held that every litigant is entitled to a righteous judgment rendered in a manner that begets no suspicion over the judge’s fairness and integrity. Consequently, the Court imposed a fine of Two Thousand Pesos (P2,000.00) with a stern warning.