A.M. No. RTJ-00-1587. May 7, 2002. OFFICE OF THE COURT ADMINISTRATOR, complainant, vs. Judge MARCELINO L. SAYO, JR., Regional Trial Court, Branch 45, Manila, respondent.
FACTS

This administrative case originated from two sworn letters of complaint against Judge Marcelino L. Sayo, Jr. The first, by court interpreter Bella Balaguer-Fabro, detailed how the judge summoned her to his chamber and forcibly detailed her to the Office of the Clerk of Court. He gave irrational justifications, such as being “disturbed” by her presence and accusing her of provoking him, and made threats like “magugulat ka na lang” if she did not transfer. This action was part of a pattern, as five employees had been similarly forced out since his appointment in 1996, causing demoralization and manpower shortage in the branch.
A second complaint, filed by several other court employees, corroborated these allegations and further accused Judge Sayo of gross misconduct, incompetence, corrupt practices, immorality, undue delay in rendering decisions, making untruthful statements in his Certificates of Service, and habitual tardiness. The Office of the Court Administrator (OCA) conducted an investigation, which substantiated many of these charges, particularly the unjust treatment of staff and delays in case resolution.

ISSUE

Whether Judge Marcelino L. Sayo, Jr. is administratively liable for his actions toward court personnel and for failing to resolve cases within the mandated period.

RULING

Yes, Judge Sayo is administratively liable. The Supreme Court found him guilty of gross misconduct, inefficiency, and undue delay. Regarding his conduct toward employees, the Court emphasized that a judge must behave with propriety and act in a manner promoting public confidence in the judiciary. Judge Sayo’s capricious and threatening removal of competent staff without valid cause, based on personal whims, constituted gross misconduct. It created an oppressive work environment and violated the Code of Judicial Conduct, which requires judges to be faithful to the law and maintain professional competence.
Concerning the delay in resolving cases, the investigation confirmed that Judge Sayo failed to decide numerous cases within the constitutionally mandated period and made untruthful certifications in his Certificates of Service regarding this backlog. The Constitution requires cases to be decided within specified periods, and a judge’s failure to comply, coupled with false certifications, constitutes gross inefficiency and undermines the administration of justice. Considering the gravity of these infractions—both the misconduct toward subordinates and the neglect of judicial duties—the Court imposed a six-month suspension without pay and benefits, with a warning for future offenses.