G.R. No. RTJ-00-1586, October 24, 2003
Thelma C. Baldado, Complainant, vs. Judge Arnulfo O. Bugtas, Regional Trial Court, Branch 2, Borongan, Eastern Samar, Respondent.
FACTS
Complainant Thelma C. Baldado, then Mayor of Sulat, Eastern Samar, filed an administrative complaint against respondent Judge Arnulfo O. Bugtas for gross ignorance of the law, gross negligence, and manifest partiality relative to Election Protest Case No. 01-98. The complaint stemmed from the judge’s August 13, 1999 Decision, which declared Zacate the winner by one vote. Baldado alleged a fatal discrepancy: while the dispositive portion (fallo) declared a one-vote margin, the decision’s body showed a mathematical tie, with each candidate garnering 2,637 votes. Following motions from both parties, the judge issued a Supplemental Decision dated August 27, 1999, admitting a “clerical error” and invalidating additional ballots, ultimately declaring Zacate the winner by two votes.
ISSUE
Whether respondent Judge Arnulfo O. Bugtas is administratively liable for gross negligence in promulgating a decision where the dispositive portion is inconsistent with the body of the decision.
RULING
Yes, the respondent judge is administratively liable for gross negligence. The Supreme Court found that the promulgation of a decision where the fallo is totally unsupported by the text constitutes a violation of the Code of Judicial Conduct, which mandates that a judge should perform all judicial duties diligently. The discrepancy between the mathematical computation in the body of the decision (a tie) and the declared winner in the fallo (a one-vote margin) was not a mere harmless clerical error. It demonstrated a failure to exercise the requisite care and diligence in crafting a final judgment, which is a fundamental judicial duty. This negligence is aggravated by the issuance of a Supplemental Decision that substantially amended the original ruling based on post-promulgation motions, further indicating a rash and unstudied approach to adjudication. While the Court noted that not every error in judgment warrants administrative sanction, a judge’s failure to ensure the internal consistency of a decision’s factual findings and its dispositive portion amounts to gross negligence. Consequently, the Court imposed a fine of Twenty Thousand Pesos (P20,000) and issued a stern warning.