A.M. No. MTJ-99-1232; February 19, 2003
ROSARIO D. ADRIANO, complainant, vs. Judge FRANCISCO D. VILLANUEVA, Metropolitan Trial Court, Branch 36, Quezon City, respondent.

FACTS

Complainant Rosario D. Adriano, the legal wife of the late Atty. Lope Adriano, charged respondent Judge Francisco D. Villanueva with gross ignorance of the law, knowingly rendering an unjust judgment, undue delay, and conduct unbecoming a judge. The administrative case stemmed from Criminal Case No. 31285 for violation of the Civil Registry Law, where the accused, Fe Floro Valino (the deceased’s live-in partner), was acquitted. Complainant alleged the judge repeatedly delayed the decision, which was submitted for resolution on October 31, 1995, but rendered only on May 20, 1997, and promulgated on August 6, 1997. She further contended the judge erroneously required criminal intent as an element for conviction under the special law and engaged in improper conduct by attempting to broker a settlement between the parties after the case was submitted for decision.
Respondent judge, in his defense, attributed the delay to his heavy caseload and explained his settlement efforts were aimed at amicably resolving the dispute. He justified the acquittal by reasoning the accused lacked intent to benefit from the falsified death certificate. He also denied the allegation of immoral conduct. The respondent had compulsorily retired on October 4, 2001, and subsequently moved for the dismissal of the administrative case.

ISSUE

Whether respondent Judge Francisco D. Villanueva is administratively liable for the charges against him, notwithstanding his compulsory retirement.

RULING

Yes, the respondent judge is administratively liable. The Supreme Court held that retirement from the judiciary does not preclude administrative accountability for acts committed during incumbency. While dismissal or suspension is no longer feasible, the Court may impose a fine deductible from retirement benefits.
The Court found respondent guilty of undue delay in rendering a decision. The case was submitted for decision on October 31, 1995, but the decision was promulgated on August 6, 1997, a delay of over one year and nine months. The excuse of a heavy caseload was unacceptable, as he could have requested an extension from the Court. This constituted a violation of the constitutional mandate to decide cases within prescribed periods.
The Court also found respondent guilty of gross ignorance of the law. He erroneously required proof of criminal intent to convict the accused under Section 9 of Presidential Decree No. 651, which amends the Civil Registry Law. Violations of this special law are malum prohibitum, where the mere commission of the prohibited act constitutes the offense, and criminal intent is not an element. His flawed legal interpretation was a basic error that eroded public confidence in the judiciary.
However, the charge of knowingly rendering an unjust judgment requires proof of bad faith, which was not sufficiently established. The charge of immoral conduct was also not substantiated by convincing evidence. The Court deemed the delay and ignorance of the law as simple misconduct and gross ignorance, respectively. Consequently, a fine of Forty Thousand Pesos (₱40,000.00) was imposed, to be deducted from his retirement benefits.