A.M. No. RTJ-05-1903; June 27, 2006
PC/INSP. MARCELO B. DAYAG, Complainant, vs. JUDGE TEODORA R. GONZALES, JUDGE HERMINIO Z. CANLAS, and ATTY. ARACELI S. CRISOSTOMO, Respondents

FACTS

Complainant PC/Insp. Marcelo B. Dayag, Chief of Police of Apalit, Pampanga, sought to file a criminal complaint for sedition following post-election unrest on May 10, 2004. He alleged that from May 10-14, the Municipal Circuit Trial Court (MCTC) of Apalit-San Simon was closed. On May 13, he proceeded to the Regional Trial Court (RTC) in Macabebe, but both RTC judges were absent. Atty. Araceli S. Crisostomo, the Clerk of Court, refused to accept the complaint, citing that the case fell under MCTC jurisdiction. Respondent Judge Teodora R. Gonzales of the MCTC reported for work on May 17, and the complaint was filed the next day. Complainant alleged Judge Gonzales delayed the preliminary investigation despite the urgency of the matter.
The administrative charges included undue delay in rendering a resolution, violation of the Code of Judicial Conduct, gross ignorance of the law, and incompetence against the judges, and gross ignorance and incompetence against Atty. Crisostomo for refusing to accept the complaint.

ISSUE

Whether the respondents are administratively liable for the charges of undue delay, violation of judicial conduct, gross ignorance of the law, and incompetence.

RULING

The Supreme Court dismissed all charges for lack of merit. For a judge to be held liable for undue delay, the law or procedure must prescribe a period within which to act, and the judge must have failed to comply. The Court found that Judge Gonzales acted within the reglementary period for conducting a preliminary investigation under the Rules of Court. The perceived urgency of the case does not shorten this legal period or constitute delay absent a specific violation.
Regarding the charges against Judge Canlas for allegedly leaving the office early and Judge Gonzales for being absent, the Court held that the complainant failed to substantiate these claims with clear evidence. Administrative liability requires proof beyond mere allegations. The Investigating Justice found the respondents’ explanations credible and in line with their official duties. As for Atty. Crisostomo, her refusal to accept the complaint was correct. As a Clerk of Court, she properly adhered to jurisdictional rules, as the crime of sedition was within the exclusive original jurisdiction of the MCTC, not the RTC. Her action demonstrated knowledge of procedure, not ignorance.
The Court emphasized that administrative complaints must be supported by substantial evidence. It warned against the filing of unfounded suits intended to harass members of the judiciary, which disrupt the administration of justice.